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    August 2020

    Sudden Pandemic-Related Closures

    Institutions resuming on-campus operations must plan ahead for a sudden closure should high community transmission rates of COVID-19 occur.


    If your K-12 school, college, or university is operating in person during the COVID-19 pandemic, ensure it’s prepared to suddenly close due to community or campus outbreaks, or public health declarations related to the pandemic. With a sudden closure, residential campuses will need to quickly move hundreds of students while keeping them physically distanced.

    Use these recommendations to guide important closure decisions.


    Assign Closure Responsibilities to Your COVID-19 Oversight Team

    The COVID-19 action team overseeing your school’s response to the pandemic should meet periodically and as needed to provide input for closure decisions. The team already should include representatives from administration, health services, and legal counsel.


    Consider Relevant Closure Factors

    The COVID-19 action team, in consultation with local and state public health officials, should determine whether a school closure may be necessary. The Centers for Disease Control and Prevention (CDC) recommends taking these factors into consideration:

    • The level of community transmission
    • Whether cases have been identified among students, especially in campus housing
    • Whether cases have been identified among staff
    • Other indicators that local public health officials are using to assess the status of COVID-19 in the area

    While the CDC recommends schools consider students’ need for in-person education for their emotional and academic growth, schools with substantial community spread of COVID-19 may need to suspend in-person academics and activities.

    Remaining open while other schools in your community close creates increased liability if the virus is transmitted on campus. Courts may look at what other institutions in the same or similar circumstances chose to do when deciding appropriate standard of care. Document your decision process (for example, what administrators knew and when). Remember that costs or loss of money, particularly when juxtaposed with human safety, are not good reasons to remain open.


    Maintain Safety During Move-Out

    Lessons learned during the spring 2020 move-out and fall 2020 move-in can help guide the need for sudden closure.

    • Stagger move-out over several days. By extending the move-out and assigning people days and times, schools can limit the human interaction normally associated with moving out of housing.
    • Require students to conduct a self-screening. Let students reschedule if they experience COVID-19 symptoms on their planned move-out day.
    • Implement coronavirus prevention practices. Require students to maintain physical distance (6 or more feet) and wear masks during move-out. Keep students who are moving out separated from other students via planned activities or a request they remain in rooms during specified move-out hours.
    • Limit the number of helpers. Allow each person up to two helpers to move out. Require helpers to remain physically distanced from other students and wear masks during move-out. Prohibit helpers who are experiencing COVID-19 symptoms.
    • Limit elevator use to one group at a time.
    • Encourage students to use their own moving and cleaning supplies. To minimize sharing items between students and visitors, ask students to use their own supplies. Make available shared moving supplies, such as bins, as needed with adequate cleaning materials and instructions.
    • Provide storage options. Institutions closing during the pandemic may not know whether the suspension of in-person academics is temporary or permanent for the remainder of the semester or academic year. Residential housing may not remain secure during these suspensions, and students may not be able to return to campus to retrieve possessions. When students are unable to take their belongings, provide access to secure, temperature-controlled, and insured storage options.

    For additional considerations, see the Sample Move-In Guidelines below.


    Support Students Who Remain on Campus

    Some students, such as international students or those under quarantine, can’t return home during a sudden closure. Determine how to continue providing housing and staffing for these students.

    The school likely has a duty of care for students allowed to live in student housing during a closure. With the help of counsel, consider implementing waivers or assumption of risk declarations for students who voluntarily remain in institution-owned housing.


    Additional Resources

    Guidance
    CDC: Interim Guidance for Administrators of U.S. Institutions of Higher Education
    CDC: FAQ for School Administrators on Reopening Schools

    Sample Policies
    University of Illinois: Fall 2020 Move-In
    University of Richmond: Move-In Guide
    Phillips Academy Andover: Opening of School Fall 2020

    By Melanie Bennett, risk management counsel


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