Coronavirus FAQs Part 3: Emergency Response and Campus Operations

Updated August 2021

As schools continue to face short- and long-term challenges from COVID-19, United Educators (UE) is here to help. The following are UE’s answers to some of the most pressing member questions regarding emergency response and campus operations associated with COVID-19.

Emergency Response

We created a COVID-19 topic page with a list of current resources. For additional guidance on implementing emergency preparedness protocols, conducting tabletop exercises, and managing crises, see UE’s emergency preparedness resources:

If your college or university is considering sharing facilities with hospitals, relief agencies, and localities, work with your broker and legal counsel to review applicable insurance and legal recommendations. With the help of legal counsel, create contracts with each hospital or government agency using the facilities, spelling out each party’s responsibilities. Ensure facility sharing planning includes a review of relevant memoranda of understanding (MOUs), insurance policies, and university policies. For additional information on facility sharing, see UE’s Sharing Campus Resources During the COVID-19 Pandemic.

Campus-wide communications about any outbreak should come from school leaders such as your President or Head of School. Establish, as part of your standing COVID response committee, an outbreak communications group to develop key messaging and oversee campus and department alerts. Include representatives from Administration, Communications, Health Services, and Legal Counsel. Prepare communications templates in advance so you can quickly release important notifications. For communications recommendations, review American College Health Association (ACHA) guidelines on campus reopening.

Department of Education (ED) guidance released on April 3, 2020, clarifies that institutions can satisfy the emergency notification requirements of the Clery Act for the COVID-19 pandemic by releasing a single notification to students and employees and creating a COVID-19 banner at the top of the institution’s homepage. Both the Clery notification and the banner should include information on the pandemic, health and safety precautions, and links to public health COVID-19 resources from health care providers, state health authorities, and the Centers for Disease Control and Prevention (CDC). Send the COVID-19 Clery notification through the regular means of communicating emergency notifications.

The guidance also clarified that the Clery Act doesn’t require institutions to give regular, ongoing updates on COVID-19 or to proactively identify positive COVID-19 cases within the campus community. Further, institutions aren’t required to release Clery Act notifications for positive COVID-19 cases among people who aren’t attending classes, working, or living on campus.

Remember that privacy laws still apply for any communications related to COVID-19. ED released a Family Educational Rights and Privacy Act (FERPA) & Coronavirus Disease 2019 FAQ with the following guidance: with the following guidance:

  • Generally, parents and eligible students must provide written consent before an institution discloses personally identifiable information (PII) from student education records to people without access to that information.
  • Student health records the institution maintains may be disclosed without consent to public health departments if the institution believes COVID-19 poses a serious risk to the health or safety of an individual student in attendance at the institution.
  • Generally, institutions may disclose to students and parents that student(s) in attendance at the school are out sick due to COVID-19 without prior written parental or eligible student consent. However, schools need to ensure that the disclosed information is in a non-personally identifiable form.

For an example of a non-personally identifiable campus communication, see Rice University’s Feb. 29, 2020, campus alert notifying the community of a possible exposure to COVID-19.

Follow ACHA COVID-19 considerations for student health services including:

  • Develop protocols for in-person and telehealth visits, advise patients to call ahead before coming into the SHC, and consider an online or telephone process for check-ins. If possible, allocate a separate area of the clinic for acute illness.
  • Consider updating screening forms to include questions on vaccination status and symptoms.
  • Screen patients and staff for COVID-19 symptoms prior to entering the SHC.
  • Train clinical and non-clinical staff to implement infection control procedures.
  • FERPA lets institutions release PII without written consent if knowledge of that information is necessary to protect the health or safety of a student or other people. Determinations under the health or safety emergency exception must be made on a case-by-case basis and take into account the totality of the circumstances pertaining to the threat. Within a reasonable time period after a disclosure under the exception, the institution must record the articulable and significant threat that formed the basis for the disclosure and the parties to whom information was disclosed from the student’s education records.
  • Develop protocols for triage and evaluation of potential COVID-19 patients using CDC guidelines.
  • Develop an internal and external communication system regarding the arrival of a potential COVID-19 patient.
  • As much as possible, stock personal protective equipment (PPE) in accordance with CDC guidelines. If PPE is in short supply, refer to the CDC’s interim infection prevention guidance for health care settings, with recommendations of acceptable alternatives and more flexible use considerations.
  • Implement environmental infection controls that are appropriate to the emerging viral pathogens that cause COVID-19, including assessing air exchange and filtration systems. CDC recommendations include ensuring consistent and correct use of environmental cleaning and disinfection procedures; routinely cleaning and disinfecting surfaces; using dedicated medical equipment when caring for patients; and managing laundry, food service utensils, and medical waste in accordance with routine procedures.
  • Review and implement surge care plans, including suspending routine care to focus on COVID-19 patients, exploring telehealth capabilities to assess and treat patients, and developing continuity of operations plans to allow for continued services.

Review the CDC’s Managing Healthcare Operations During COVID-19 for additional, up-to-date information.

Campus Operations

The institution’s policies regarding protection of minors also should apply to online interactions and virtual instruction.

Continue the same precautions your school would have on campus, including:

  • Limit or forbid one-on-one interactions with minors in a private setting.
  • Define allowable communication between teachers and students (for example, don’t allow electronic communication with minors except when there is a clear educational purpose, and recommend copying the parent on all communications).

Additionally, schools may wish to use communication platforms that allow the school to archive activity. For more information on protecting minors, see UE’s checklist series for K-12 and Higher Ed and UE’s Protecting Children Learning Program.

Reiterate that school policies against harassment and discrimination remain in place. Continue to respond to and investigate reports of misconduct, even when it occurs over a remote learning or communication tool. Send campus communications condemning severe or pervasive incidents of discrimination affecting the campus community. For example, the University of Houston-Victoria released a nondiscrimination statement on the university’s COVID-19 webpage. For additional information for K-12 schools, see UE’s article on Combating Cyberharassment at K-12 Schools.

When deciding whether to allow in-person student activities such as clubs and athletics, weigh the activities’ importance to students’ personal growth and educational experience against the health, safety, and liability risks the COVID-19 pandemic poses. Consider whether certain activities associated with clubs and athletics may be conducted remotely, including safety training or orientation.

For any in-person activities, make participation phased and voluntary. With the help of your school’s COVID-19 action team, create an activity resumption plan that outlines how you will restart any in-person activities and detail activity modifications to meet campus safety requirements and COVID-19 policies. Consider whether safety measures such as wearing masks or physical distancing are appropriate (see Coronavirus Part 4: Vaccinations, Study Abroad, COVID Policies for additional guidance on mask and physical distancing policies). Also consider whether enforcement practices, such as collecting a signed acknowledgment, creating an assumption of risk or waiver, or adding language to the student code of conduct, are right for your institution to help conduct activities safely.

Communicate regularly with participants and/or parents about safety policies and changes in conditions.

For additional athletics considerations and guidelines, review the NCAA’s Sport Science Institute COVID-19 page. For guidance regarding all activities including athletics, consult In-Person Activities and Athletics and the ACHA’s Considerations for Reopening Institutions of Higher Education for the Fall Semester 2021.

By Christine McHugh, JD, Senior Risk Management Counsel, and Melanie Bennett, JD, Senior Risk Management Counsel

More From UE
Coronavirus Part 1: Campus Health and School Closures
Coronavirus Part 2: Employment Practices
Coronavirus Part 4: Vaccinations, Study Abroad, COVID Policies

Note for UE members: UE’s risk management advice is distinct from the coverage provided under its policies. To understand UE’s insurance coverage for COVID-19 testing and vaccination efforts, administrators responsible for your institution’s insurance program should read UE’s coverage advisory.