Guide For Resuming On-Campus Operations

Schools should continue to providea robust online offering throughoutthe pandemic.Remote OptionsOffering an online option has important liabilityreducing benefits. For example, students oremployees who are not offered a remote option topursue their work or studies may be owed a higherduty of care from the institution, to keep themsafe. However, if students or employees are offeredmeaningful choice but select to come on campus,they may be deemed to assume the risks. (See Assumption ofRisk Forms and Waivers section below.)Online options may be a useful component of plans to putphysical distancing into place. They also allow schools tobetter transition all students to virtual learning if there isa resurgence of cases or an outbreak on campus. Schoolsshould continue to provide a robust online offeringthroughout the pandemic.CommunicationGood communication with students, employees, and otherrelevant constituents is critical for maintaining a senseof calm and reducing potential liability. The resumptionplanning period is a good time to re-evaluate ad-hoccommunications teams or practices previously createdduring the crisis. Review your institution’s communicationspractices and make changes as necessary.Team Identify a central supervisory team to vet all pandemiccommunications. To ensure the communications team isproperly informed and informing the resumption process,members of the communications team should report to,and include members from, the oversight team. Include representatives from the president’s office,communications, health services, IT, and legal counsel.6/16Guide for Resuming On-Campus OperationsPractices Establish a protocol requiring that school leaders, suchas the president or head of school, send all campus-widepandemic-related communications. Work with legal counsel to ensure all communicationsfollow privacy laws including the Family EducationalRights and Privacy Act (FERPA) and Health InsurancePortability and Accountability Act (HIPAA).Messaging Describe COVID-19 mitigation efforts broadlyacross campus communications, including employeehandbooks, student handbooks, codes of conduct, andresidential housing contracts. Emphasize the need for all community members tocontribute and do their part to assist in efforts tomitigate the virus.Education and TrainingImplement online COVID-19 awareness and preventiontraining to help faculty and students adjust to the newreality before arriving on campus. Many online trainingsare available, including brief instructional videos onthe CDC’s YouTube channel. Other free trainingswww.EduRiskSolutions.org

incorporating CDC information are also widely available.If training is conducted in person, ensure physicaldistancing and face coverings are strictly enforced.The World Health Organization (WHO) and CDCrecommend that COVID-19 prevention training includethese concepts: Physical distancing (maintaining at least a 6-footdistance from people outside your household, avoidinglarge crowds, not touching people if you do not need to) Good health behaviors such as cough and sneezeetiquette (covering coughs and sneezes with the elbow)and hand hygiene (washing hands for 20 seconds withsoap and water) How germs can spread Proper use and maintenance of cloth face coverings andother relevant PPE The benefits and limitations of wearing PPE (forexample, cloth face coverings are meant to protect otherpeople in case the wearer is unknowingly infected butdoes not have symptoms) High-risk behaviors, such as coming to school with acold, and modifying behaviors, such as staying homewhen sick Signs and symptoms of COVID-19 and how to conducta self-assessment What to do if you are sick (using CDC guidance) What to do if you recently had a close contact with aperson with COVID-19 (using CDC guidance)The CDC also recommends publicizing the nationalDisaster Distress Hotline, a mental health resourcethat provides crisis counseling and support to peopleexperiencing emotional distress related to natural orhuman-caused disasters.Supplement general prevention and control training withcontent on institution-specific COVID-19 policies andprocedures. Reinforce the new policies and proceduresthrough campus signage, social media posts, and schoolcommunications.Assumption of Risk Forms and WaiversTo help limit liability, institutions are considering waiverand assumption of risk language specific to the currentpandemic. When used with meaningful education aboutpreventing the spread of the virus, the risks of contracting it,and the institution’s own policies for reducing its prevalence,Consult with legal counsel before implementing assumption of risk or waiver language.7/16Guide for Resuming On-Campus Operationswww.EduRiskSolutions.org

waiver or assumption of risk language makes injuredsignors less likely to bring a claim. It can act as leverage fornegotiating the settlement of a claim, can persuade a courtto dismiss a negligence lawsuit, and can serve as powerfulevidence at trial. Consult with legal counsel beforeimplementing assumption of risk or waiver language.Assumption of RiskConsider using informational letters or modifying currentdocuments with assumption of risk language to informstudents and parents of the risks involved with returning tocampus during a pandemic.Examples of assumption of risk language: The student is aware that returning to campus for the[Fall 2020] semester is voluntary. The student acknowledges that COVID-19 is a publichealth risk, and [the institution] cannot guarantee safetyor immunity from infection, and that the student iselecting to return to campus despite the risks. The student voluntarily assumes all risks associated withreturning to campus including the risk of exposure orinfection with COVID-19.Additional examples of assumption of risk and waiverlanguage are included in the Additional Resources sectionbelow.Require students (and all parents, if minor students) to signthe document, acknowledging that they understand andvoluntarily assume the risks described. When issuing thedocument, provide the signing parties time to review andconsider the document.WaiversWhether to implement a waiver for students returning toschool is a business decision for each institution to makein consultation with legal counsel. Although waivers mayrelease institutions from potential liability, enforcementvaries greatly by jurisdiction and the waiver’s underlyingsubject matter. Additionally, when dealing with studentswho are minors, courts are traditionally reluctant toenforce a waiver. In fact, most benefits from a waiver donot hinge on a court’s determination that the documentis an enforceable waiving of rights, but on the signor’sacknowledgment of the risk assumed, created througha clear communication of risk in the document. (Foradditional guidance on assumption of risk language, seebelow and see UE’s Checklist: Drafting Effective Releases.)Educate Before Issuing the Assumptionof Risk or WaiverProvide students and parents with the waiver andassumption of risk language as part of your institution’sCOVID-19 training and education. Explain what thelanguage means, describe each risk, and describe howcampus life will be impacted. Give students and parentstime to review and consider the document before signing.Retain the Waiver or Assumption of RiskRecord the receipt of all waiver and assumption of risklanguage. In the event of a lawsuit, this record may showthat the student was warned of the risks and voluntarilyreturned to campus.8/16Guide for Resuming On-Campus Operationswww.EduRiskSolutions.org

Part II: Practical ConsiderationsInstitutions that can resume on-campus operations will need to modify regular policies and practices tocreate a safe campus. After institutions decide to resume, the oversight team should consider implementingthese recommendations. The team also should identify and document any recommendations it does notimplement due to the institution’s particular circumstances.Phased ReturnFacilitiesMany institutions should implement a hybrid academicmodel, providing both on-campus and online learning, forthe foreseeable future. The on-campus learning portion ofthe hybrid model should be implemented using a phasedapproach. Consider the following ACHA guidance increating your institution’s phased approach.Educational facilities were not built with the intention ofkeeping people physically distanced. For more detailedfacilities recommendations, see APPA’s Recently AskedQuestions. To best prepare facilities to resume operations,consider the following cleaning, occupancy, andconfiguration recommendations.Faculty and Staff Limit the return to employees who volunteer. Prioritizethose with the greatest ability and desire. At least once a day, clean and disinfect school buildings,classrooms, sanitation facilities, residences, and otherregularly used buildings and rooms. Follow CDCcleaning and disinfecting recommendations. Return no more than 30% of the workforce at a time,staggering every two to four weeks for full return. Use of shared objects (lab equipment, computerequipment, desks) should be limited when possible, orcleaned between use. Stagger employee schedules to promote social distancingpractices. Maintain at least 6 feet between workstations. Placebarriers in shared workspaces.Academics Space chairs and desks to ensure physical distancing. Forlecture halls, consider taping off seats and rows. To limit the number of students on campus at any onetime, have students attend alternate days or semesters, oradopt a half-day model. Turn desks to face the same direction (rather than facingeach other). Limit the number of attendees for in-person courses andprograms. In most cases, in-person courses should belimited to fewer than 30 participants and use physicaldistancing measures. Create multiple sections or shifts to reduce numbers ofstudents in a shared space. Prioritize in-person instruction for courses with academicoutcomes that cannot be measured or achieved virtually,such as performance, laboratory, and clinical experiences. Keep a fully remote option ready in the event of arebound in local infections necessitating continuedphysical distancing.9/16Guide for Resuming On-Campus Operationswww.EduRiskSolutions.org

Place signage at entrances indicating how to proceed.(For example, should visitors wait at the entrance beforeproceeding to limit the number of people waiting in anenclosed space?) Post and enforce maximum allowed occupancy in sharedspaces such as conference rooms, waiting rooms, andbreak rooms. Provide hand sanitizer or hand-washing stations at allentrances and high-traffic areas. Provide touchless door options such as door removal,card access, foot-operated door pulls or pedals, or sensortriggered doors. Install Plexiglas barriers at high-traffic areas such asreception desks. Provide physical guides, such as tape on floors orsidewalks and signs on walls, to ensure that individualsremain at least 6 feet apart in lines and at other times. Increase air flow and ventilation where climate allows(open windows, use air conditioning). Install touchless trash cans. Ensure trash is removed daily and disposed of safely.Campus ResidencesBecause traditional student housing limits physicaldistancing, consider discontinuing or limiting on-campushousing. For institutions that choose to reopen residences,consider the following recommendations. Provide all live-in professionals and other residentialstaff, including custodial, with:{Access to PPE{Appropriate break opportunities{Defined work schedules with time off as appropriate{Access to mental health services, such as counseling{Specific training and education Educate residential staff on CDC recommendationsincluding:{{{{ To ensure the safety of water systems, follow CDCguidance for reopening buildings after prolongedshutdown.Consider special needs or accommodations for highrisk residents, such as people with disabilities, peoplewith underlying medical conditions, and older adults.Limit staff entering residents’ rooms or livingquarters unless it is necessary. Use virtualcommunications and check-ins as appropriate.Consider any special communications and assistanceneeds of the residents, including people with disabilities.Suggest residents keep up-to-date lists of medicalconditions and medications, and periodically checkto ensure they have a sufficient supply of theirprescription and over-the-counter medications (athigher ed institutions). Where feasible, limit housing to a single resident perroom and bathroom. When shared bathrooms are used, create guidelineslisting maximum occupancy and cleaning proceduresthat include the following CDC guidelines:{{{{{10/16Guide for Resuming On-Campus OperationsClean at least twice per day using EPA-registereddisinfectants.Continuously stock bathrooms with soap and papertowels or automated hand dryers.Empty trash cans regularly.Provide signage on proper hand-washing or use ofhand sanitizer.Instruct residents to avoid placing toothbrushesdirectly on sinks and counters, as both can be sourcesof infection.www.EduRiskSolutions.org

Create CDC-conformant cleaning plans for residencesand bathrooms that state how and how often surfaceswill be disinfected. Periodically review the plans basedupon appropriate disinfectant and PPE availability.Dining Services Require personal face coverings in common areas. Require diners to wear cloth face covers while in thefacility, except when eating. Close non-essential common areas (lounges, game rooms). Reconfigure seating in common areas (computer rooms,entrance halls) to ensure physical distancing. Establish and enforce allowable occupancy in essentialcommon areas. Clean and disinfect between use. Minimize traffic in elevators and stairwells by limitingthe number of individuals in an elevator at one timeand designating one-direction stairwells. Create floormarkings in the elevator where users should stand. Prohibit building access by non-residents, except asrequired by law. For example, do not prohibit access bypersonal care attendants who are helping residents withdisabilities. Identify isolation and quarantine rooms with privatebathroom facilities that are physically separated fromother residential student rooms. With the help of legalcounsel, provide signage restricting access withoutviolating HIPAA/FERPA. Require all dining facility staff to wear cloth face coversand gloves while working and interacting with the public. Identify maximum allowable occupancy in a singledining facility at one time, with a goal of achievingappropriate physical distance. Establish dining times for all community members. Place visual cues, such as 6-foot floor markers for waitinglines, inside and outside the facility. Space tables and limit numbers of chairs per table. Eliminate buffet and self-serve food or beverage stations. Provide a bagged take-out meal option. Consider kosher,vegetarian, vegan, and gluten-free options as requestedor appropriate. Consider serving meals in classrooms (for K-12 schools). Arrange food delivery to students in isolation orquarantine. In isolation or quarantinerooms, follow the CDC’sguidance for cleaning anddisinfecting householdswith suspected orconfirmed coronaviruscases. This includesfocusing on cleaning anddisinfecting commonareas where staff andothers providing servicesmay come into contactwith ill people, butreducing cleaning anddisinfection of bedroomsand bathrooms used by illpeople (so they are onlycleaned as needed).11/16Guide for Resuming On-Campus Operationswww.EduRiskSolutions.org

Faculty and StaffAs previously noted, faculty and staff who can do their jobsremotely still should have that option. For those who returnto campus, consider the following policies and practices.Additionally, create and publicize a reporting mechanismallowing faculty and staff to report safety violations. Create a culture where employees who developCOVID-19 symptoms stay home or leave the workplace.Consider what policies your institution can implementthat will encourage sick employees to stay home for theduration of their illness. Cross-train staff and create a roster of trained backupstaff to allow for increased absenteeism. Ensure that housekeeping receives PPE and guidelineson appropriate techniques (as per CDC guidelines) forcleaning and disinfecting workspaces and common spaces. Create new policies in the handbook or contract including:{{{{Maintain a 6-foot distance from others during work.Wear CDC-conformant cloth face covers while oncampus. Employees may remove their face coverswhile conducting business (teaching, sitting at theirdesk, etc.) as long as they remain 6 feet from others.Conduct meetings electronically, even when workingon campus.Avoid office gatherings, break rooms, andunnecessary visitors. Encourage staff and faculty at higher risk forsevere illness to self-identify so they can receiveaccommodations such as telework and remote classes. Develop policies and procedures for employees toreport when they are sick or experiencing COVID-19symptoms. Ensure that people who have signs orsymptoms immediately isolate or leave campus and seekmedical advice. Follow Occupational Safety and Health Administration(OSHA) guidelines for investigating an employee’sCOVID-19 illness by doing the following:{{{Ask employees how they believe they contractedCOVID-19.While respecting employees’ privacy, discuss theirwork and out-of-work activities that may have led tothe COVID-19 illness.Review an employee’s work environment forpotential COVID-19 exposure. Stagger shifts to reduce the number of people in theworkplace at the same time. Encourage single occupancy in work rooms and offices. Issue personal teaching supplies (microphones, markers,electronic pointers) to avoid sharing of supplies betweenfaculty members. Issue employees personal office supplies to avoid sharing. Provide and strongly encourage flu vaccinations to limitadditional viruses during the COVID-19 pandemic.Travel Prohibit all nonessential international travel while theState Department maintains a Level 4 Global Do NotTravel Advisory and the CDC maintains a Level 3 GlobalHealth Travel Notice. Because pandemic experts predict a future COVID-19surge, discourage or consider prohibiting nonessentialinternational and domestic travel until a vaccine iswidely available.12/16Guide for Resuming On-Campus Operationswww.EduRiskSolutions.org

StudentsWhere possible, continue to provide students with aremote learning option even as in-person classes resume.For students who return to campus, consider the followingconsiderations. Develop attendance and excuse policies that supportstudents who become ill, without requiring unnecessaryvisits to health facilities for documentation of illness. Incorporate COVID-19 policies into the studenthandbook. Policies may include:{{{{13/16When possible, maintain a 6-foot distance fromothers while on campus.When possible, wear CDC-conformant cloth facecovers while on campus. Consider whether studentsmay remove their face covers while sitting in class solong as they rema

1/16 Guide for Resuming On-Campus Operations www.EduRiskSolutions.org Guide for Resuming On-Campus Operations In these unprecedented times, schools and colleges continue to struggle with how to provide educational services during the COVID-19 pandemic. When it comes to decisions about re