Will College Campuses Open Soon? CDC Guidance Offers Considerations

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The Center for Disease Control (“CDC”) recently issued guidance specific to reopening college campuses. Though the CDC did not weigh in on whether institutions should resume in-person classes in the fall, it set forth key considerations an institution should contemplate when making the decision. Among other issues raised, the CDC guidance outlines a number of strategies institutions should consider to reduce the spread of COVID-19, maintain a safe and healthy environment, protect the physical and mental health of employees and students, and prepare to respond if a member of the community gets sick. The guidance does not contain mandates, recognizing instead that schools must be given leeway to work with state and local health officials to come up with plans that fit their needs based on factors such as geography and culture.  

Promoting Behaviors that Reduce Spread 

The CDC guidance recommends that institutions consider several strategies to reduce the spread of COVID-19. First, if a decision is made to have any version of in-person classes, institutions should actively educate students, faculty, and staff on when they should stay home or self-isolate. The CDC recommends that institutions develop policies that encourage sick individuals to stay at home without fear of reprisals and offer remote learning or telework options to those individuals when self-isolating.  

The CDC also recommends promoting good hand hygiene and “respiratory etiquette.” This includes but is not limited to: 

  • Recommending and reinforcing the use of face coverings among students, faculty, and staff
  • Ensuring there are adequate hygienic and disinfecting supplies throughout the campus, and 
  • Posting signs in highly visible locations (e.g., building entrances, restrooms, dining areas) that promote everyday protective measures and describe how to stop the spread of germs. 

As a reminder, under current Illinois guidance, face coverings are required at all times unless the individual has a medical condition or disability that would prevent the safe use of the face covering or the face covering would not be otherwise safe to wear.  

Maintaining Healthy Environments 

The guidance recommends implementing the following strategies to maintain a safe and healthy environment:   

  • Cleaning and disinfecting frequently touched surfaces (such as door handles, sink handles, drinking fountains, grab bars, hand railings, bathroom stalls, dining hall tables) within all facilities at least daily or between use
  • Ensuring adequate supplies to minimize sharing of high-touch materials to the extent possible (such as assigning each student their own art supplies, lab equipment, computers) or limiting the use of supplies and equipment by one group of students at a time and cleaning and disinfecting between use
  • Ensuring ventilation systems operate properly and increasing circulation of outdoor air as much as possible (such as opening windows and doors)
  • Modifying layouts such as spacing seating/desks at least six feet apart; taping off seats and rows in lecture halls to ensure six-foot distance between seats; hosting smaller classes in larger rooms; and offering distance learning in addition to in-person classes to help reduce the number of in-person attendees
  • Installing physical barriers such as sneeze guards and partitions and providing physical guides, such as tape on floors or sidewalks and signs on walls to ensure that individuals remain at least six feet apart
  • Closing shared spaces such as dining halls, game rooms, exercise rooms, and lounges and adding physical barriers, such as plastic flexible screens, between bathroom sinks and between beds especially when they cannot be at least six feet apart
  • Providing grab-and-go options for meals rather than buffet or self-serve stations and using disposable food service items (such as utensils and dishes)

Maintaining Healthy Operations 

The CDC guidance provides suggestions for protecting the physical and mental health of employees and students. According to the CDC, institutions should encourage telework “for as many faculty and staff as possible” and consider offering (although, per the EEOC, not requiring) employees at a higher risk of severe illness due to age or underlying medical conditions the ability to telework or take on modified job responsibilities. Similarly, institutions should allow students who are in a vulnerable class the opportunity to participate in virtual instruction. The CDC also recommends limiting sizes of gatherings, restricting “nonessential visitors” and activities involving external groups, and implementing communications plans and flexible sick leave policies. 

Preparing for When Someone Gets Sick 

Finally, pursuant to the guidance institutions should be prepared to advise sick faculty, students, and staff of home isolation criteria, to implement and enforce protocols for isolating and transporting sick students, faculty and staff, and to appropriate notify health officials and close contacts of people who have been diagnosed with COVID-19. 

Again, the CDC guidance neither permits nor prohibits the reopening of college campuses, but rather provides the above strategies and considerations to help institutions act in the best interest of its students, staff, and the community. Given the wide range of geographic locations, size, structure and tolerance for risk among the thousands of institutions across the United States, the CDC made clear that higher education institutions can determine, in collaboration with state and local health officials, whether and how to implement the suggested considerations while adjusting to meet the unique needs and circumstances of the school and local community. The CDC also recognized that implementation should be guided by “what is feasible, practical, and acceptable, and should be tailored to the needs of each community.” 

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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