Abbott: COVID-19 and our Schools

June 18, 2020

by Jeff Abbott, Ph.D.

Updated by the CDC on May 19, 2020

Introduction.

Introduction: Shortly after the release of the Center of Disease Control (“CDC”) COVID-19 guidelines for schools on May 19, 2020, Orange County Public Schools superintendent said on an Orlando television station that the CDC guidelines would be “a challenge” for the school district. This is what the reader will soon see is one huge understatement. The CDC offers certain considerations to help “protect students, teachers, administrators, and staff and slow the spread of COVID-19.”  First, it is important to understand that CDC only offers “considerations” and does not issue rules or mandates to schools. The CDC clearly states:

“Schools can determine, in collaboration with state and local health officials to the extent possible, whether and how to implement these considerations while adjusting to meet the unique needs and circumstances of the local community. Implementation should be guided by what is feasible, practical, acceptable, and tailored to the needs of each community.” Further the CDC states that their considerations are “meant to supplement—not replace—any state, local, territorial, or tribal health and safety laws, rules, and regulations with which schools must comply.”

This paper is intended to give the reader some insights into the CDC guidelines as well as the practicably and feasible of the implementation in the public schools of America. The CDC guidelines are in italics throughout this paper.

CDC’s Guiding Principles. 

“The more people a student or staff member interacts with, and the longer that interaction, the higher the risk of COVID-19 spread. The risk of COVID-19 spread increases in school settings as follows:

• Lowest Risk: Students and teachers engage in virtual-only classes, activities, and events.
• More Risk: Small, in-person classes, activities, and events. Groups of students stay together and with the same teacher throughout/across school days and groups do not mix. Students remain at least 6 feet apart and do not share objects (e.g., hybrid virtual and in-person class structures, or staggered/rotated scheduling to accommodate smaller class sizes).
• Highest Risk: Full sized, in-person classes, activities, and events. Students are not spaced apart, share classroom materials or supplies, and mix between classes and activities.”

Author’s Comments:  This guideline is mostly common sense. It may serve as a good over-all  thought process and help schools categorize each risk as they begin to open up their buildings. This assessment of risk by the CDC may however be of limited use to school district personnel as it so basic to be obvious to all those who manage public schools.

CDC Suggestions for Promoting Behaviors that Reduce Spread.

The CDC suggests that schools may consider implementing several strategies to encourage behaviors that reduce the spread of COVID-19.

• Staying Home when appropriate
• Educate staff and families about when they/their child(ren) should stay home and when they can return to school.
  • Actively encourage employees and students who are sick or who have recently had close contact with a person with COVID-19 to stay home. Develop policies that encourage sick employees and students to stay at home without fear of reprisal, and ensure employees, students, and students’ families are aware of these policies. Consider not having perfect attendance awards, not assessing schools based on absenteeism, and offering virtual learning and telework options, if feasible.
  • Staff and students should stay home if they have tested positive for or are showing COVID-19 symptoms.
  • Staff and students who have recently had close contact with a person with COVID-19 should also stay home and monitor their health.

Author’s Comments: Staff and students staying home when sick with the COVID-19 is a good common-sense idea. But the devil is in the details, as will be discussed below. The CDC does not define “appropriate” as to when to stay home.  Nor does the CDC say for how long students and staff should stay home.  Not having attendance awards, not assessing schools based on absenteeism (during the pandemic only) and offering virtual learning options should be acceptable ideas to all schools and state departments of education.

• CDC’s criteria can help inform when employees should return to work:
  • If they have been sick with COVID-19
  • If they have recently had close contact with a person with COVID-19

Author’s Comments:  It would have been more helpful for schools if the CDC would have presented in these guidelines their criteria for employees to return to work. Schools are left to search for this return to work criteria in other CDC documents.

• Hand Hygiene and Respiratory Etiquette
  • Teach and reinforce handwashing with soap and water for at least 20 seconds and increase monitoring to ensure adherence among students and staff.
    • If soap and water are not readily available, hand sanitizer that contains at least 60% alcohol can be used (for staff and older children who can safely use hand sanitizer).

Author’s Comments:  Handwashing with soap and water for at least 20 seconds is one of the more helpful guidelines issued by the CDC. Most, if not all Americans have seen CDC promo spots on this. Whether people will actually comply with this suggestion is another matter. Also, it might be helpful if the CDC would clarify the handwashing guideline — does it require the hands to be flushed with water for the full 20 seconds or does the time spent soaping up the hands count against the 20 second requirement? One other question, how is the school to increase its “monitoring” of this handwashing compliance? Will it have to hire bathroom monitors?

• Encourage staff and students to cover coughs and sneezes with a tissue. Used tissues should be thrown in the trash and hands washed immediately with soap and water for at least 20 seconds.
  • If soap and water are not readily available, hand sanitizer that contains at least 60% alcohol can be used (for staff and older children who can safely use hand sanitizer). 

Author’s Comments:  Handwashing after each sneeze and each cough certainly sounds helpful in an effort to contain the virus. In practice, however, this will result in a lot more trips to the bathrooms, particularly those students who find this is a great way to leave the classroom to roam around in the hallways. Again, the monitors will of course have to accompany these students to the bathroom each trip.

• Cloth Face Coverings
  • Teach and reinforce use of cloth face coverings. Face coverings may be challenging for students (especially younger students) to wear in all-day settings such as school. Face coverings should be worn by staff and students (particularly older students) as feasible and are most essential in times when physical distancing is difficult. Individuals should be frequently reminded not to touch the face covering and to wash their hands frequently. Information should be provided to staff, students, and students’ families on proper use, removal, and washing of cloth face coverings.
    • Note: Cloth face coverings should not be placed on:
      • Children younger than 2 years old
      • Anyone who has trouble breathing or is unconscious
      • Anyone who is incapacitated or otherwise unable to remove the cloth face covering without assistance
  • Cloth face coverings are meant to protect other people in case the wearer is unknowingly infected but does not have symptoms. Cloth face coverings are not surgical masks, respirators, or other medical personal protective equipment.

Author’s Comments:  These guidelines should be well received by school staff.  Hopefully the CDC is not expecting students and staff to use facemasks all day… as this is not likely to happen. Perhaps the most realistic expectation is that when 6-foot distancing does not happen that students and staff will put on their face masks.

• Adequate Supplies
  • Support healthy hygiene behaviors by providing adequate supplies, including soap, hand sanitizer with at least 60 percent alcohol (for staff and older children who can safely use hand sanitizer), paper towels, tissues, disinfectant wipes, cloth face coverings (as feasible) and no-touch/foot-pedal trash cans.

Author’s Comments:  These adequate supplies requirements are all good and necessary but will increase costs for schools with all the new handwashing requirements. Also, schools generally do not have no-touch/foot-pedal trash cans, so all new trash cans will need to be purchased by schools.

• Signs and Messages
  • Post signs in highly visible locations (e.g., school entrances, restrooms) that promote everyday protective measures and describe how to stop the spread of germs (such as by properly washing hands and properly wearing a cloth face covering).
  • Broadcast regular announcements on reducing the spread of COVID-19 on PA systems.
  • Include messages (for example, videos) about behaviors that prevent the spread of COVID-19 when communicating with staff and families (such as on school websites, in emails, and on school social media accounts).
  • Find free CDC print and digital resources on CDC’s communications resources main page.

Author’s Comments:  Again, these rather basic and simple suggestions by the CDC would in all likelihood be implemented by schools even absent all these “guidelines.” Thus, these are not all that new or helpful to public school managers. 

CDC Suggestions for Maintaining Healthy Environments.

Schools may consider implementing several strategies to maintain healthy environments.

• Cleaning and Disinfection
  • “Clean and disinfect frequently touched surfaces (e.g., playground equipment, door handles, sink handles, drinking fountains) within the school and on school buses at least daily or between use as much as possible. Use of shared objects (e.g., gym or physical education equipment, art supplies, toys, games) should be limited when possible, or cleaned between use.” 

Author’s Comments:  This rather innocuous looking “guideline” is the first of significant costs to implement. First of all, assuming school custodial staff are already occupied with meaningful and necessary duties, this “guideline” will require hiring of additional custodial help to perform all these new cleaning duties. Depending on the physical size of the school and student enrollment, at least a half time custodian, or if the school is larger, at least one full time up to two full time custodians will need to be hired. 

• If transport vehicles (e.g., buses) are used by the school, drivers should practice all safety actions and protocols as indicated for other staff (e.g., hand hygiene, cloth face coverings). Schools should also develop a schedulefor increased, routinecleaning and disinfection.

Author’s Comments:  School bus drivers, other than picking up trash left by students, or the occasional student vomit, are typically not required to disinfect and thoroughly clean their school buses after each trip to and from school. Either the school district will be required to pay drivers for the new cleaning services as it will take considerable time to clean and disinfect each seat, or the district will need to hire additional cleaning employees to clean and disinfect buses at night. This cost will not be insignificant either way.

• Shared Objects
  • Discourage sharing of items that are difficult to clean or disinfect.
  • Keep each child’s belongings separated from others’ and in individually labeled containers, cubbies, or areas.
  • Ensure adequate supplies to minimize sharing of high touch materials to the extent possible (e.g., assigning each student their own art supplies, equipment) or limit use of supplies and equipment by one group of children at a time and clean and disinfect between use.
  • Avoid sharing electronic devices, toys, books, and other games or learning aids.

Author’s Comments:   Unfortunately, schools do not have an anti-sharing culture as this guideline promotes. If adopted, it would certainly change the culture of schools. There will also be additional costs to the school district as most districts will have to purchase additional supplies, equipment, toys, books, games, learning aids, and computers for each individual student. This can easily cost tens of thousands dollars for even the smallest of schools, and hundreds of thousands or more for large secondary schools.

• Ventilation
  • Ensure ventilation systems operate properly and increase circulation of outdoor air as much as possible, for example by opening windows and doors. Do not open windows and doors if doing so poses a safety or health risk (e.g., risk of falling, triggering asthma symptoms) to children using the facility.

Author’s Comments:  There will be many days in the fall, spring and summer that are hot weather days. Opening windows and doors could result in classroom temperatures well over 100 degrees Fahrenheit. These classrooms will not only be extremely uncomfortable for students and teachers, but learning will be adversely affected as its just to hot to think and learn. Further, keeping doors and windows open could endanger students who are allergic to bees and wasps. Its good the CDC recognizes that this might pose a risk to asthmatic students, but what the CDC appears not to understand, is that nearly every classroom will have one or more students with some degree of asthma or serious allergies to pollen. Finally, opening doors and window can present a security risk to students and teachers. 

• Water Systems
  • To minimize the risk of Legionnaire’s disease and other diseases associated with water, take steps to ensure that all water systems and features (e.g., sink faucets, drinking fountains, decorative fountains) are safe to use after a prolonged facility shutdown. Drinking fountains should be cleaned and sanitized, but encourage staff and students to bring their own water to minimize use and touching of water fountains.

Author’s Comments.  Wow won’t this be fun… arming students with water bottles. Apparently, the CDC did not see the recent riots in many American cities. Thousands of pictures exist showing rioters throwing full water bottles at the police as their way of participating in a new sport…waterballing. Yes, many public schools are full of students who hassle authority figures, and some of the rioters were students in high school. It is not a stretch to predict students will be throwing bottles and each other as well as school staff.

• Modified Layouts
  • Space seating/desks at least 6 feet apart when feasible.  

Author’s Comments:  It might have been helpful if prior to issuing this suggestion, a member of the CDC would have visited a few classrooms in K-12 schools. They would have soon seen the infeasibility of this suggestion. Even if schools removed all storage, cabinets, learning centers, and learning equipment, most school classrooms will lack the space to put each desk 6 feet apart. This will require millions of dollars in new construction for new classrooms if schools are to comply with this suggestion.

• Turn desks to face in the same direction (rather than facing each other), or have students sit on only one side of tables, spaced apart. 

Author’s Comments:  If there is sufficient space, which is a big if, then this is not an additional cost burden to schools. However, this type of classroom arrangement will set schools back over 50 years in terms of learning style arrangements. Decades ago, researchers established that students learn better when they learn in groups cooperatively. This discussion and interaction among students cannot occur in the “new” learning environment advocated by the CDC.  Is this the CDC’s idea of “Back to the Future” which starred Michael Foxx?

• Create distance between children on school buses (g., seat children one child per row, skip rows) when possible.  

Author’s Comments:  Although every bus driver in America would love this idea, it is just not sensible. This would result in school buses operating at about 16.67% capacity on elementary runs where 3 students per seat are usually shuttled, and 25% capacity on high school runs where at least two students per seat are shuttled.  There are basically only three ways to accomplish this student distancing on a school bus: (1) extend the walking distance by several more miles, and only transport the few students who live far away from the school; (2) at least quadruple the number of school bus runs, which might well result in the first run beginning at 3:00 a.m. and the last run arriving at 10:00 a.m. or even 11:00 a.m. depending on distance traveled. Schools are simply not staffed to provide supervision at such early hours, nor are they staffed to run schools in shifts like a factory; and (3) purchasing new school buses four times the number of school buses the school currently operates (costing millions of dollars for an average size school district) and hiring about 4 times the number of school bus drivers currently employed by the school district – costing at least hundreds of thousands of dollars each year for a typical sized school district, and millions of dollars each year for large school districts.  It is just not practical for this suggestion to be implemented.

• Physical Barriers and Guides
  • Install physical barriers, such as sneeze guards and partitions, particularly in areas where it is difficult for individuals to remain at least 6 feet apart (e.g., reception desks). 

Author’s Comments:  Won’t this be a pretty sight! Three or four foot “sneeze guards and partitions” surrounding the reception desks. Why protect only receptionists? You of course would intend to provide the same protection to administrators, counselors, social workers, nurses, teachers, and students – they all need protection too, right? This idea must be right out of Rod Sterling’s’ “The Twilight Zone”, as the scene of all these guards and partitions would appear to look like one big rat maze. It would depersonalize schools and make face to face interaction more difficult.

• Provide physical guides, such as tape on floors or sidewalks and signs on walls, to ensure that staff and children remain at least 6 feet apart in lines and at other times (e.g. guides for creating “one way routes” in hallways).  

Author’s Comments:  This suggestion would work well… in a 1950’s school. How long would it take for a student bent on mischief to peal off the tape the school placed on its floors and sidewalks.  Sadly, in many public schools it won’t take long. Unless the school can tear out walls to make more hallways, “one way routes” in hallways won’t work, as every school hallway in America was designed for two way hallways. 

• Communal Spaces
  • Close communal use shared spaces such as dining halls and playgrounds with shared playground equipment if possible; otherwise, stagger use and clean and disinfect between use.  

Author’s Comments:  Now the CDC is going from the inane to the absurd. A school without a dining room. How ridiculous! Would the CDC want the students to eat outside  in 80-90 degree summer weather, or 10-20 degree winter weather?  Or in school hallways, perhaps, or even worse – in classrooms?  Kids spill a lot of food in the cafeteria. Custodians after each lunch period sweep the cafeteria and pick up considerable trash that students drop on the floor. Can you imagine the stench in each classroom that kids eat in by the end of the school day, especially on days when syrup is served? To suggest lunch periods be staggered (presumably to keep the 6 foot social distancing) would require some student to eat shortly after arriving to school and some eating shortly before departure. How about schools that serve breakfast? Lunchrooms will not be available soon enough for the early lunch periods. Has anyone in the CDC set foot in a public school the last couple of decades?

The CDC is not content to just abolish lunch rooms. Now they move on to effectively abolish recess for kids! It is absurd to think schools can purchase individual playground equipment so that the equipment is not “shared.” All playground equipment is shared. Kids don’t play in their own little bubble – they play together.

• Add physical barriers, such as plastic flexible screens, between bathroom sinks especially when they cannot be at least 6 feet apart. 

Author’s Comments:  In many schools this may be feasible but will have an economic cost. Plus it’s just one more thing for wayward students to vandalize. Hey CDC, how about “plastic flexible screens” around the urinals?

• CDC Guidelines for Food Service
  • Have children bring their own meals as feasible, or serve individually plated meals in classrooms instead of in a communal dining hall or cafeteria, while ensuring the safety of children with food allergies. 

Author’s Comments:  See above comments regarding communal spaces.

• Use disposable food service items (e.g., utensils, dishes). If disposable items are not feasible or desirable, ensure that all non-disposable food service items are handled with gloves and washed with dish soap and hot water or in a dishwasher. Individuals should wash their hands after removing their gloves or after directly handling used food service items.  

Author’s Comments: Ok… but schools already do this as nearly all, or all, state and county boards of health require this procedure, except they do not require disposable food service items. 

• If food is offered at any event, have pre-packaged boxes or bags for each attendee instead of a buffet or family-style meal. Avoid sharing food and utensils and ensure the safety of children with food allergies.  

Author’s Comments:  This guideline makes sense. It is simple and straightforward. I think schools would do this even absent a federal agency guideline.

CDC Suggestions for Maintaining Healthy Operations.

Schools may consider implementing several strategies to maintain healthy operations.

• Protections for Staff and Children at Higher Risk for Severe Illness from COVID-19
  • Offer options for staff at higher risk for severe illness (including older adults and people of all ages with certain underlying medical conditions) that limit their exposure risk (e.g., telework, modified job responsibilities that limit exposure risk).  

Author’s Comments:  This rather vague guideline appears to be an intrusion of the CDC into local school district’s personnel matters. Who determines whether “staff is at higher risk for severe illness? What are the standards and measurement system to determine this “higher risk”? Higher than whom or what? How long must, or can, a school employ staff for “telework” (whatever that is) and modified job responsibilities? Do some students get a real live classroom teacher and others just a talking head on the computer? Will additional staff have to be employed? Does the CDC pay for this additional cost?

• Offer options for students at higher risk of severe illness that limit their exposure risk (e.g., virtual opportunities learning).

Author’s Comments:  This rather vague guideline appears to be an intrusion of the CDC into local school district’s curriculum and student management matters. Who determines whether students are “at higher risk for severe illness”? What are the standards and measurement system to determine this “higher risk”? Higher compared to whom or what?  Do some students sit at home and watch a talking head on the computer teach them, while others get a real live classroom teacher? Will additional staff have to be employed? Does the CDC pay for this additional cost?

• Consistent with applicable law, put in place policies to protect the privacy of people at higher risk for severe illness regarding underlying medical conditions.  

Author’s Comments:  What is the “applicable law”? Why not state in the CDC guidelines what this law is?  The HIPPA federal law already protects the privacy of people’s medical matters. Why does the CDC believe that other policies are needed?

• Regulatory Awareness
  • Be aware of local or state regulatory agency policies related to group gatherings to determine if events can be held.

Author’s Comments:  This may prove to be a very helpful piece of advice from the CDC. Some school staff may not be aware of their state’s regulations as to how many people can gather in the bathroom, kitchen, closets, or offices. This may be why the CDC issued this guidance to “be aware of local or state regulatory agency policies related to group gatherings.” Does the CDC really think it necessary to advise school staff to follow local and state regulations, when public education is one of the most highly regulated industries in America?

• Gatherings, Visitors, and Field Trips
  • Pursue virtual group events, gatherings, or meetings, if possible, and promote social distancing of at least 6 feet between people if events are held. Limit group size to the extent possible.

Author’s Comments:  Most schools have been shut down for several months. Schools have used various software programs to hold virtual group events, gatherings, and meetings. Perhaps the most, if not only, helpful advice for schools is to distance people 6 feet apart if groups of people meet.

• Limit any nonessential visitors, volunteers, and activities involving external groups or organizations as possible – especially with individuals who are not from the local geographic area (e.g., community, town, city, county).

Author’s Comments:  What is the difference between and essential visitor, volunteer, or activity, versus “nonessential”? Who gets to decide? Who decides, and what standards do they use, to determine if limiting is “possible”?  What is an “external group or organization”? Is it the PTA, Junior Achievement, Antifa? If the Governor comes to a school, since the Governor is not from the same “local geographic area”, does a school deny access to the Governor? How about the State Fire Marshall, or State Police? This writer is pretty sure school management has the sense to limit access to schools to the extent necessary to keep students reasonably safe, e.g. requiring temperature checks for visitors and volunteers, denying those poor visitors or volunteers who just got off a cruise ship, or recently came back from traveling to Wuhan China or other foreign country.

• Pursue virtual activities and events in lieu of field trips, student assemblies, special performances, school-wide parent meetings, and spirit nights, as possible.

Author’s Comments:  Finally, some evidence that somebody involved in the development of the CDC guidelines has at least visited a public school within the past couple of decades. Schools have done an admirable job the past several months in not having field trips, student assemblies, special performances, school-wide parent meetings, and spirit nights – as the have been closed and locked up by the Governors. However, these activities are all essential and necessary activities of a school. These activities have proven to be the best tool to build parent and public support for schools. When schools open up they need to conduct these activities “when possible”.

• Pursue options to convene sporting events and participation in sports activities in ways that minimizes the risk of transmission of COVID-19 to players, families, coaches, and communities.

Author’s Comments:  How helpful is this guideline? What might be the ways to “minimize the risk of transmission of COVID-19 to players, families, coaches, and communities”?  Hold sporting events without any parents or community in the grandstands? Change tackle football to flag football with the defense players using 6 foot poles to rip the flag off the runner? Requiring basketball players to keep a 6 foot distance from all other players? (Coaches want good offensive spacing for their team for the passing game, but this is not what they have in mind for defense – a  team who tries to guard the opponents from 6 feet away will give up a lot of points.)

• Identifying Small Groups and Keeping Them Together (Cohorting)
  • A group of children stays with the same staff (all day for young children, and as much as possible for older children).

Author’s Comments:  Having the same teacher all day in elementary school is somewhat problematic. What about art teachers, music teachers, and physical education teachers that most schools have employed? Do they get laid off when each teacher teaches their own art, music, and P.E.? What about preparation time for these elementary school teachers when they have used the special classes time for their preparation?

Secondary schools are even more problematic. Does the CDC really want the social studies teacher teaching physics, the P.E. teaching biology, the chemistry teacher teaching history? Even keeping the same students together is not feasible, as students want and take different elective courses.  

• Limit mixing between groups if possible.

Author’s Comments:  Not even sure what the CDC means by “limit mixing between groups if possible”. Schools are inherently high contact social institutions. They are not conducted with a bubble around each person in the school. In fact, it can be argued that without high social contact learning will not occur. Kids will soon be bored when kept in isolation.

• Staggered Scheduling
  • Stagger arrival and drop-off times or locations by cohort or put in place other protocols to limit contact between cohorts and direct contact with parents as much as possible.

Author’s Comments:  Here is a simple idea… the CDC could put up a ten million dollar prize for any school administrator who is able to develop and successfully implement a plan for the staggered arrival and drop-off times and locations by cohort – without cost increase to the school district. Good PR for the CDC, and essentially a zero probability the CDC would ever have to make the payout. This guideline calls for schools to operate in shifts like a factory. It will have little, if any, staff, parent, or public support. 

• When possible, use flexible worksites (e.g., telework) and flexible work hours (e.g., staggered shifts) to help establish policies and practices for social distancing (maintaining distance of approximately 6 feet) between employees and others, especially if social distancing is recommended by state and local health authorities.

 Author’s Comments:  These guidelines are essentially a repeat of other guidelines presented by the CDC above. Although maintaining 6 foot social distancing is an admirable guideline, it will be quite a challenge for public schools. Perhaps the CDC could provide each teacher and each student with an oxygenated plastic bubble to put on when at school. Holes must be placed in the mouth area for feeding however, defeating the purpose of the bubble. Going to the bathroom might be a little difficult too. Perhaps a select committee established by the CDC could figure out how to solve this bathroom problem.

• Designated COVID-19 Point of Contact
  • Designate a staff person to be responsible for responding to COVID-19 concerns (e.g., school nurse). All school staff and families should know who this person is and how to contact them.

Author’s Comments.  No problem – just assign this duty to the school nurse… and watch ‘em yelp. Does the CDC have any idea how much time this will take?  The author certainly has no idea. If this requires nurses to work over-time, or schools to hire another part-time nurse to implement this guideline, will the CDC pay for these extra costs?

• Participation in Community Response Efforts
  • Consider participating with local authorities in broader COVID-19 community response efforts (e.g., sitting on community response committees).

Author’s Comments:  Ah yes, the bureaucrats dream… establish a committee community-wide so nobody has responsibility for student and staff safety.  The CDC is off the hook for any responsibility because they adopted all these wonderful guidelines and called for another community response committee.

• Communication Systems
  • Put systems in place for:
    • Consistent with applicable law and privacy policies, having staff and families self-report to the school if they or their student have symptoms of COVID-19, a positive test for COVID-19, or were exposed to someone with COVID-19 within the last 14 days in accordance with health information sharing regulations for COVID-19 (e.g. see “Notify Health Officials and Close Contacts” in the Preparing for When Someone Gets Sick section below) and other applicable federal and state laws and regulations relating to privacy and confidentiality, such as the Family Educational Rights and Privacy Act (FERPA).

Author’s Comments:  It would have been helpful for the CDC to identify what “applicable law and privacy policies” to which they refer. Perhaps they don’t know what these are? Also, it would have been helpful for the CDC to identify the “applicable federal and state laws and regulations relating to privacy and confidentiality”, other than FERPA. 

“Having staff and families self-report to the school if they or their student have symptoms of COVID-19, a positive test for COVID-19, or were exposed to someone with COVID-19 within the last 14 days in accordance with health information sharing regulations for COVID-19” is a sound idea and easy to understand.

• Notifying staff, families, and the public of school closures and any restrictions in place to limit COVID-19 exposure (e.g., limited hours of operation).

Author’s Comments:  Another excellent idea from the CDC to keep staff, families, and the public informed of school closures and any restrictions in place to limit COVID-19. Surely the school’s public relations staff appreciates this advice.

• Leave (Time Off) Policies and Excused Absence Policies
  • Implement flexible sick leave policies and practices that enable staff to stay home when they are sick, have been exposed, or caring for someone who is sick.
    • Examine and revise policies for leave, telework, and employee compensation.
    • Leave policies should be flexible and not punish people for taking time off, and should allow sick employees to stay home and away from co-workers. Leave policies should also account for employees who need to stay home with their children if there are school or childcare closures, or to care for sick family members.

Author’s Comments:  Quite simply this guideline usurps the authority of every state legislature in the country as well as every school board that has had delegated to it the power to establish personnel policies. Further, most school boards already have in place generous sick leave policies, and many have family paid leave policies. Schools are best managed by local authorities and not by a federal agency located in Atlanta, Georgia. Finally, the CDC does not provide any funding for this new intrusion into the management of school personnel policies

• Develop policies for return-to-school after COVID-19 illness. CDC’s criteria to discontinue home isolation and quarantine can inform these policies.

Author’s Comments:  Although this again is the CDC making personnel policy for schools, schools may find the CDC guidelines to discontinue home isolation and quarantine to be helpful – if they can find them. Unfortunately, the CDC did not include its advice in these guidelines and schools are left to find it in another CDC document. 

• Back-Up Staffing Plan
  • Monitor absenteeism of students and employees, cross-train staff, and create a roster of trained back-up staff.

Author’s Comments:  All schools do monitor student and employee absenteeism and don’t need this guideline from the CDC.  There is some cross-training of staff. It is not clear from the guideline which type of staff should be cross-trained and what kind of training they should undertake. “Back-up staff” is not a term normally used in schools. Does the CDC mean substitute teachers and substitute staff? If so, schools already have rosters of these substitutes, although with the wide-open leave policies for staff recommended by the CDC, schools may have to double their roster of “back-up staff”.

• Staff Training
  • Train staff on all safety protocols.
  • Conduct training virtually or ensure that social distancing is maintained during training.

Author’s Comments:  School staff is typically trained on various safety protocols. The CDC does not describe the safety protocols they want as training. So until that is done, school management will be in the dark.

• Recognize Signs and Symptoms
  • If feasible, conduct daily health checks (e.g., temperature screening and/or or symptom checking) of staff and students.
  • Health checks should be conducted safely and respectfully, and in accordance with any applicable privacy laws and regulations. School administrators may use examples of screening methods in CDC’s supplemental Guidance for Child Care Programs that Remain Open as a guide for screening children and CDC’s General Business FAQs for screening staff.

Author’s Comments:  Daily temperature and symptom checking sounds innocuous and smart. It probably needs to be done to reassure staff that no staff or students are knowingly arriving to school sick. It won’t definitely inform as to COVID-19 specifically as a high temperature or similar symptoms may be an illness other than COVID-19. Further consideration should be the cost of this checking. It would probably be a school nurse. In a small school of 30-40 staff members, this simple task could take a couple of hours of the nurse’s work day. In a larger school of 100 or more staff members, this may take half or more of the nurse’s work day. This has a cost factor as school nurses are often overworked, and it is likely schools will have to hire additional nurses at least part-time. This will be very difficult given the shortage of nurses in most areas. 

• Sharing Facilities
  • Encourage any organizations that share or use the school facilities to also follow these considerations.

Author’s Comments:  It is not clear as to which considerations each outside organization must follow. Boy Scouts would not likely have the same considerations as AAU girls volleyball. 

• Support Coping and Resilience 
  • Encourage employees and students to take breaks from watching, reading, or listening to news stories about COVID-19, including social media if they are feeling overwhelmed or distressed.
  • Promote employees and students eating healthy, exercising, getting sleep, and finding time to unwind.
  • Encourage employees and students to talk with people they trust about their concerns and how they are feeling.
  • Consider posting signages for the national distress hotline: 1-800-985-5990, or text TalkWithUsto 66746.

Author’s Comments.  These items may be well received by school staff as they will take minimal time to accomplish and have only nominal cost, the cost of the signages.

• Preparing for When Someone Gets Sick

Schools may consider implementing several strategies to prepare for when someone gets sick.

• Advise Staff and Families of Sick Students of Home Isolation Criteria
  • Sick staff members or students should not return until they have met CDC’s criteria to discontinue home isolation.
• Isolate and Transport Those Who are Sick
  • Make sure that staff and families know that they (staff) or their children (families) should not come to school, and that they should notify school officials (e.g., the designated COVID-19 point of contact) if they (staff) or their child (families) become sick with COVID-19 symptoms, test positive for COVID-19, or have been exposed to someone with COVID-19 symptoms or a confirmed or suspected case.
  • Immediately separate staff and children with COVID-19 symptoms (such as fever, cough, or shortness of breath) at school. Individuals who are sick should go home or to a healthcare facility depending on how severe their symptoms are, and follow CDC guidance for caring for oneself and others who are sick.
  • Work with school administrators, nurses, and other healthcare providers to identify an isolation room or area to separate anyone who has COVID-19 symptoms or tests positive but does not have symptoms. School nurses and other healthcare providers should use Standard and Transmission-Based Precautions when caring for sick people. See: What Healthcare Personnel Should Know About Caring for Patients with Confirmed or Possible COVID-19 Infection.
  • Establish procedures for safely transporting anyone who is sick to their home or to a healthcare facility. If you are calling an ambulance or bringing someone to the hospital, try to call first to alert them that the person may have COVID-19.

Author’s Comments:  All of these guidelines are straightforward and easily implemented by school staff. There should be no additional costs for schools when they implement these suggestions.

• Clean and Disinfect
  • Close off areas used by a sick person and do not use these areas until after cleaning and disinfecting
  • Wait at least 24 hours before cleaning and disinfecting. If 24 hours is not feasible, wait as long as possible. Ensure safe and correct use and storage of cleaning and disinfection products, including storing products securely away from children.

Author’s Comments:  Although these guidelines seem simple and well intended, and should be done, in some cases implementation will close down school for a day or more. If a child attends school all day, walks the hallways, uses the gym and cafeteria, all these will need to be cleaned. Can we spell custodial “overtime” folks? If schools have to wait 24 hours to occupy these areas, except on Fridays, the school could have to shut down for a day or more.

• Notify Health Officials and Close Contacts
  • In accordance with state and local laws and regulations, school administrators should notify local health officials, staff, and families immediately of any case of COVID-19 while maintaining confidentiality in accordance with the Americans with Disabilities Act (ADA).
  • Inform those who have had close contact with a person diagnosed with COVID-19 to stay home and self-monitor for symptoms, and follow CDC guidance if symptoms develop.

Author’s Comments:  Since the ADA may prohibit schools from revealing the name of the ill person, the notification will not include the person’s name. By requiring a student or staff member to stay home raises some new legal issues. First, who is, if anybody, required to pay the employee’s wages for time missed by that employee whose only sin was he or she had “close contact” with a person who has COVID-19? What are the employer’s rights – can the employer require the employee to stay home when the employee wants to work? How about students and symptom-free who refuse to stay home after having “close contact” with some person who has the virus? If a student sits 5 feet, or maybe 4 feet, from another student in the lunchroom who was the next day diagnosed to have the virus, does the school have the legal power to order a student to stay home who has been so exposed? How does this guideline interface with state mandatory attendance laws? Does this guideline supersede state laws, and state constitutions, that provide that public schools must be open to all? Does requiring a student so exposed to stay home deny a student his or her right to a public education, particularly when the student has no symptoms? How long can the school require the exposed student to stay home? These are just a few of the many legal questions presented by implementation of these guidelines.

Author’s General Comments:  The CDC is likely full of educated well-meaning people with respected medical degrees and great expertise in communicable diseases. The guidance they have provided for public schools is surely well-intended.  However, the guidelines appear to have been issued in a void without the input and collaboration of public school superintendents,  principals, and teachers. The guidance seems to perhaps be solid medical advice, but lacks context and knowledge of public schools.  No two schools, and no two school districts are alike.

It is very difficult, if not impossible, for a federal agency from Atlanta, Georgia to develop rules, guidelines, or suggestions that are helpful for schools all over America. This is just one more example of the federal government trying to micromanage schools from afar. When will politicians and federal bureaucrats ever learn that they cannot successfully run schools by fiat, regulations, even “suggestions”  issued from the federal law palaces?

The politicians and bureaucrats will probably respond: “But these are just guidelines and suggestions – not mandates!” Be that they may… how difficult will be for public schools not to follow these guidelines? Very difficult! Politically it will be difficult for schools. Once the first few kids get sick and the school has not followed all the guidelines, the parents and community activists will be visiting the next school board meeting in masse screaming the school was not responsible and   mismanaged the re-opening of schools. In that same crowd at the board meeting will likely be a couple of plaintiff’s lawyers eagerly handing out their business cards to parents who will soon sign lawyer agreements and become plaintiffs in lawsuits alleging negligence, malfeasance, wrongful death, etc., etc., etc.  Once again, the public schools have been placed by the politicians and bureaucrats in the overly used trick bag.

Jeff Abbott, J.D., Ph.D., an adjunct scholar of the Indiana Policy Review Foundation, until his retirement was assistant professor of education at Purdue University Fort Wayne. A former superintendent of the East Allen County School District, Dr. Abbott was selected by Indiana Superintendent of Public Instruction Tony Bennett to serve on his transition team. He is the author of numerous articles and papers on education reform.

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