Coronavirus Recommendations for Resuming On-Campus Operations

Host: Hello and welcome to today’s webinar, Coronavirus Recommendations for Resuming On-Campus Operations. Note that all attendees are in listen-only mode. Today’s program will be approximately 60 minutes long. Because today’s program is pre-recorded, we will not be taking live questions. However, please let us know if you need help with any technical questions or concerns. Simply enter your question or comment in the question box on the bottom of your screen and click “Submit.” Your submitted questions will be visible only to the technology team. Webinar resources are available in the resources list to the right of the presentation. And now here’s today’s moderator, Melanie Bennett.

Melanie Bennett: Thank you, and welcome to our program. I’m Melanie Bennett, risk management counsel at United Educators. I’m pleased to introduce our speakers, Jean Chin and Hayley Hanson. Dr. Chin is chair of the American College Health Association’s COVID-19 Task Force. Welcome, Jean.

Jean Chin: Thank you, Melanie.

Bennett: Hayley Hanson is a partner at the Husch Blackwell law firm. Thank you for joining us, Hayley.

Hayley Hanson: Thanks, Melanie.

Bennett: You can view the speakers’ full bios on the side of the page. A few housekeeping items before we begin. First, the webinar audio recording plus the PowerPoint, transcript, and resources, should be available on our risk management website,, within the next two weeks. Second, this webinar is pre-recorded. Although we will not answer live questions during this webinar, a technical team is watching the comments. If you experience major technical issues, please submit your issues using the Q&A box. Third, I want to reiterate that today we’re addressing risk management concerns created by the coronavirus pandemic, and we’re not addressing coverage considerations in this webinar. Finally, although Hayley and I are lawyers, the webinar is not designed to provide legal advice.

Here’s our agenda for today: We’re going to start with Jean, who’s going to talk about public health recommendations. After that, Hayley will talk about legal considerations. At the end, I’ll briefly discuss some UE recommendations and resources. We’ll have a total of three Q&A sessions during the program to answer the submitted questions. Now let me turn it over to Jean so she can provide public health recommendations.

Chin: Thank you Melanie, and once again, thank you for allowing ACHA to come and speak on our reopening guidelines. Today we are approaching 2 million cases of COVID-19 in the United States and over 120,000 deaths. So we don’t see an easy end in sight just yet.

Starting with campus preparation, the role of campus preparation is critical in this pandemic and requires the type of interdisciplinary engagement that must involve people who can readily deploy resources without constantly having to run things up the flagpole. Your planning should include developing or refining your incident action plans and playing out every single what-if scenario to the very end.

Ideally, your executive leadership is actively engaged and informed so they can communicate effectively to your stakeholders and make sound decisions based on current knowledge. There is absolutely no doubt that we will see students with COVID-19. A student with symptoms should be evaluated and tested at the Student Health Service or their primary care provider and sent home or self-quarantined. If they are confirmed positive, you must notify the local health district.

You need to isolate that student at home or in a designated isolation area in the residence hall. You need to assist the health department with contact tracing and quarantine any exposed students for 14 days and test contacts who become symptomatic.

College health has long been known to sit at the intersection between education and health on the campus, and your Student Health Services is the keystone to the campus public health response. The health services provides an advisory, care delivery, and care coordination role. They have the capability to translate complex scientific information into practical and understandable context for the campus, thus providing the necessary background required to develop evidence-informed policies, procedures, and protocols.

For those campuses without a Student Health Services, you should, right now, develop your partnerships with the health department and the community.

During this time before classes resume, your Student Health Services must maximize its assets including developing and strengthening your key campus and community partnerships, procuring necessary supplies, budgeting appropriately to account for COVID-19-related expenses and lost revenue, and preparing the staff and the facility for a new normal in delivering patient care.

You must communicate the new care delivery model to the campus community and the Student Health Services must train and support the staff, address high-risk employees, and develop any policies for exposures. Depending on the phase of the pandemic, class sizes should really be less than 50 ─ and probably more like 30 ─ while utilizing strict physical distancing guidelines. You need to develop seating charts, take roll so you can monitor and track attendance ─ and that helps facilitate contact tracing, if there is indeed a student who becomes infected.

Those who are medically vulnerable should consider continuing a remote option until conditions improve. You need to develop plans for labs, clinical experiences, internships, out-of-classroom experiences, and ensure those students have adequate and appropriate PPE. Performing arts students, theater, band, orchestra, choral societies, dance students all pose particular challenges and will require innovative instruction.

We know that viral droplets are transmitted with talking, but loud speech, singing, and the closer the proximity and the longer the exposure time, is a recipe for transmission. Substituting or enhancing live patient clinical experiences with the sim labs should be strongly considered. We know that not all students can learn well remotely or have access to adequate technology or WiFi, and those students will need definite support.

When fully opened, thousands to tens of thousands of students may live and dine on a campus during periods of full in-person instruction. Students are often living with two or more individuals per room, with roommates from different parts of the country in the world, all with different levels of prevalence. In our guidelines, we recommended the ideal scenario of a single person in a single room with a single bathroom. Many institutions though, we realize, don’t have the housing inventory for that, so the next best is two per room with a shared bathroom.

Other recommendations include restricting visitors and all of those other public health prevention practices that you’re probably tired of hearing about: wearing face coverings in public, washing your hands, physical distancing, covering your cough. The questions that institutions are struggling with right now are whether high-risk individuals should come back to on campus housing in the first wave or simply wait, and how many rooms to set aside for quarantine and isolation.

I’ve seen estimates from 2% to 7% of the housing inventory being set aside. Dining areas are often large and chaotic, with closely spaced tables and chairs and both sustained and episodic and tons of interpersonal interactions. The rules of engagement apply here as well. Define your maximum occupancy, consider scheduling groups of students in a block, enforce physical distancing, hand sanitizing, and face coverings except when eating, of course. Grab and go options are ideal.

Replace buffets and self-serve stations with a staff member who serves food if you can. Food Services needs to coordinate with housing and Student Affairs for food delivery to students in isolation or quarantine in on campus housing. Portable handwashing stations and food trucks or ample supplies of alcohol-based drugs are mandatory.

You should be evaluating your facilities and identifying those places which could be high transmission risks right now if you haven’t done it yet. Is the Plexiglas barrier the best solution, is signage sufficient, or can you simply reconfigure furniture, chairs, and desks, which is the cheapest option. Designate separate doors for entry and exit if you can to decrease cross-contamination, two people in an elevator with face coverings, probably no more than four.

Encourage stairs if you can, and can you designate those stairs to be unidirectional? So one set of stairs to go up and one set of stairs to go down like an escalator. Visual cues with tape or stickers on the floor or physical barriers to keep people 6 feet apart is ideal. Anything communal, you need to get rid of. Remove your magazines and those communal candy dishes got to go. Support hand hygiene with ample alcohol-based hand rub or soap and plenty of water, paper towels, and other supplies if you have it.

You cannot open the doors until your workforce is prepared and protected. They need information which could be provided through a formal training module and the same basic information should be given to all employees and incoming students. The content should include basic prevention and public health practices as well as campus specific guidance, and even when you all return to campus, virtual meetings should continue in order to decrease exposures and the need for frequently deep cleaning meeting spaces.

Your housekeeping and custodial staff should be thoroughly trained and given PPE for cleaning and disinfecting as per CDC guidance, and gradually bring your workforce back. You can determine the percentage. Could be 20%, 30%, but stagger them over two to four weeks. Bring your most vulnerable staff back last. All staff should self-assess their temperature and symptoms and stay home if sick. Finally, here is a link to our ACHA guidelines that we released on May 7.

Bennett: Thanks Jean. I want to quickly remind everyone that the recent ACHA guidelines are also available in the resources box of this webinar. Now we’ll answer some of the submitted questions. Jean, here’s the first question. How can schools continue to safely conduct performing arts programs that traditionally require human contact?

Chin: Thank you, Melanie for that question, and actually conducting a performing arts program is probably the most challenging endeavor. I mean, for goodness sake, Broadway is still closed for a reason. The performing arts is really not my wheelhouse, but one of the safest approaches is just remaining physically distanced. So physical distancing and Zoom classes though can only go so far. So small in-person classes that remain physically distanced, that would be fine. So just two, three, four people. Some have advocated for treating dance students like student-athletes and performing initial testing and some scheduled retesting frequency on them along with the daily screening. I would be very interested to hear what other innovative approaches that listeners could share because that is probably one of the most dangerous scenarios.

Bennett: The next question asks, what screening protocols do you recommend before allowing students on campus?

Chin: That’s another one of those, it depends. It depends on the population discussed, Melanie. So universally though on a daily basis, students should self-assess for fever, respiratory symptoms as per CDC guidance, and if they have any of those symptoms, they need to go straight to their primary care provider or call the Student Health Services. Individuals though returning internationally, they need to self-quarantine for 14 days and be tested if they develop symptoms.

Similarly, students who have traveled domestically but coming from states with high cases like Florida ( that’s on fire right now) should quarantine for 14 days before coming to campuses. Some schools are performing viral testing on specific cohorts of students like those living in residential housing, or athletes, and hopefully soon CDC will be releasing testing guidance for institutions of higher education.

Bennett: Thank you, Jean. Now let’s go to Hayley for an overview of the legal considerations.

Hayley Hanson: Thanks, Melanie. As you can imagine, there’s a whole host of legal considerations that colleges and universities should be considering as they’re returning to campus. And we’re going to talk about a few of them today. One of the things I’d like to say at the beginning of my presentation, is make sure that your campus counsel or outside counsel is really working with you on these legal considerations to try to minimize your risk.

First, let’s talk about personal injury claims and tort liability. So obviously, if you are a public institution, you may have sovereign immunity that does not allow tort claims to be brought against your institution, but if you do live in a state that doesn’t have sovereign immunity, or if you’re a private institution, it’s important to really understand what types of claims could be brought as you’re looking at return to campus.

One really good resource is written by James Keller, talking about liability considerations for return to campus. And it was put out in a NACUA note on May 27. It’s a very good resource and covers more in-depth some of the things we’re going to talk about today.

So, let’s break down these theories of liability. First, landowner liability. This is essentially the theory of liability that because a school owns land that you know about the risk of COVID-19 and you’re inviting people to your land. If you fail to protect them or exercise reasonable care to protect them, then there’s a theory of liability. So what all of these definitions really talk about is this concept that as Jean spoke about, whatever your plan is for return to campus, you need to make sure that you are following your plan, and that you are not over committing in a plan document to things that you cannot actually carry out on your campus.

The next theory of tort theory of liability is negligence per se. That is really if a state passes a law saying that every landowner must take specific actions to protect against the risk of a viral transmission and the school does not take those actions and someone is harmed and argues this theory of liability. Then the last is one that I was just speaking of earlier, gratuitous undertaking, and this rule applies to institutions that do take steps to mitigate the impact of COVID-19 but don’t implement them properly.

People who contract COVID-19 on their campus, if they can show that they’ve contracted it on their campus, could argue that the school increased their risk of getting sick because they relied on their mitigating measures, and that because they didn’t follow through on those measures, there was harm that was caused.

So let’s talk about practical considerations to reduce risk or protect against liability: What do those look like? I think following up on Jean’s comments, again, making sure that there’s an interdisciplinary working group that is putting forth your plan, your mandates, and making sure that you are following the practices set forth by the CDC, local health agencies, and getting that information together in terms of how your institution will move forward.

Also, I think it’s important that you have stakeholder buy-in across campuses, or multiple campuses or a single campus, to make sure that the plan that you’re putting together works for your institution. There’s a lot of different pieces of that that we’re going to talk about, but it includes notifying your constituencies, your students, your parents, your employees, about what to expect when they return to your institution, and really considering having an individual who’s in charge of implementing this plan that individuals can go to if they believe they have something to report or if they believe that there’s an issue with the particular plan.

Then finally, do what you say you’re going to do. If you have a plan, and you are making sure that your constituencies know about that plan through training, through other measures, make sure that you’re following up and showing how that plan is being implemented. I want to be very clear that I think everyone assumes that these plans may change depending on what happens as we come back to campus. That’s OK, but make sure that you are following through on whatever testing protocols that you have identified, and information that you are going to provide to your constituencies as they return to campus.

So a lot of institutions have been asking us about assumption of the risk forms and waivers, and really the difference between the two and what they should be thinking about as they return to campus. So assumption of the risk forms really educate participants of known and unknown risks associated with a specific activity such as returning to campus, and a waiver releases a party from liability for specific claims.

Now, what is important about these two things is that state law really differs when it comes to assumption of the risk forms or waivers, because these are risk mitigation documents. That’s why you’re using them, that if you get sued by somebody, and you are trying to defend your lawsuit, one, the waiver could become a bar to the actual claim, and the assumption of the risk form becomes an affirmative defense upon which you could rely on.

So it’s extremely important, again, that you work with your local attorneys or that you work with your campus legal counsel to make sure that you understand how your state approaches these types of forms and that you have appropriate language in these forms to make sure that they’re legally enforceable. So some of the potential advantages of these types of documents are it makes the injured parties less likely to bring claims. But it doesn’t eliminate risk. We cannot do that.

It also acts as leverage in negotiating when you’re talking about a settlement, if somebody has signed a waiver or an assumption of the risk. Again, it also could persuade a court to bar a claim or potentially even rely on the assumption of the risk form as an affirmative defense. It serves as very powerful evidence if you get to court which, again, as we know, most cases do not. But if you do get to court, it’s a very powerful document to be using, with the cross examination of the plaintiff, to say, “We told you all of these things prior to coming back to campus, and you agreed, and here’s your signature.” That can be powerful testimony for a jury.

So let’s talk about how to increase the likelihood that these types of forms or waivers are actually enforceable if you would have a situation in which you’d have a lawsuit pending against the institution. One of the things that you can do to make these forms more enforceable is educate on the known and unknown risks of COVID-19, and be very clear that you cannot prevent the spread even with our mitigating measures, that there are risks, and make sure you’re educating your constituencies that you want to have sign this document in that particular document.

Also, make sure that you describe how those risks are going to be related to areas that Jean really talked about. To living arrangements, roommates, communal bathrooms, extracurriculars, dining, all of those types of things, that you want to be able to describe how those risks increase. It’s also important that you explain that the institution is taking preventative measures to lessen the transmission of COVID-19, but again, it’s impossible to say that we’re going to prevent the transmission.

Require participants to acknowledge the voluntariness of this decision and the fact that that individual is electing to participate despite the risks that they have been notified of. This is important, because part of your plan has to be, to be able to provide other alternatives if someone is not willing to take on these risks, and that can be online learning, a variety of different options for students in the alternative of having to come back to campus. So think about that as well. Also, the forms really need to incorporate legal terms such as negligence that we talked about and assumption of the risk were needed.

Then I think the formatting is very important as well, to make sure that you’re bolding these types of statements and or even underlining, that you’re really drawing the reader’s attention to the statements of what they’re agreeing to within the assumption of the risk form or the waiver. Finally, I think it’s very important that all those that are required to sign these forms, those that are going to sign the forms, not only turn them back into the institution to keep a copy, but also keep a copy themselves, because you’re probably going to identify things that you’re asking them to do, and to agree to, especially as Jean talked about, monitor their own symptoms, and notify us if there are symptoms that you think would lead to a potential diagnosis of COVID-19.

Those types of things will need to be in the forms and waivers as well. Then finally, just, I’ll say it again, I’m sorry I’ve said it before, but the specific requirements really do vary by state. So make sure that you have looked at this from your state perspective as well as legal perspective and make that determination.

Bennett: Thanks, Hayley. Now we’ll take a few more questions. The first question asks, “Can colleges or school districts require students and employees to wear masks?”

Hanson: I think that’s a great question, and the answer to that question is, yes. I think you can have policies that require employees and require students to wear masks. I think the question becomes, what are you going to do if they don’t wear masks, and what does discipline look like under your plan or your policy and that’s something you want to think through, and especially if you’re a state higher education institution or school district, versus a private institution, and what are your remedies if you don’t have people that will comply.

Bennett: Thank you. The next question asks, “Should schools create waivers for all students in dorms?”

Hanson: So, again, as we talked about earlier, I think the difference between an assumption of risk form and a waiver is something you really need to look at for your specific state and have your legal counsel weigh in on. I do think some sort of form for those individuals that are living on campus and your residence halls is going to be important, because there are things that you just cannot protect the students from. So it’s going to be important for them to get that information early to understand what the plan is by the institution and to be able to understand what their obligations are regarding reporting, regarding wearing PPE or other types of preventative measures. So I think those are the keys that you want to look at when identifying what’s best for your institution between a waiver and an assumption of the risk form.

Bennett: Our next participant is interested in communications. They ask, “How should schools communicate their new policies and practices?”

Hanson: So a lot of schools have created a COVID-19 banner on their website, and I do think it’s important that you have some sort of page in which you can direct constituencies to, whether that be your faculty and staff and your employees or your students to make sure that information is in one place. So looking at that webpage, make sure you were posting information there. I also think it’s important when we talk about extracurricular activities or other types of activities that could pose additional risk, that training is very important.

So as students are coming back, as employees are coming back, look at what types of training you can do to promote this information across your campus. Now, I know that may differ from really large campuses to smaller campuses may be able to handle the training easier, but think about how you want to approach that and make sure that, again, the information is accessible, it’s easy to find, and that to the extent you can do a training.

I also have really recommended, if you can’t get in person to everyone training, because that’s not feasible right now, a lot of schools are doing Zoom trainings, and they’ve been very well attended, and those Zoom trainings can be recorded and then put on your website as well. So just a few ideas for you.

Bennett: That’s a great note. Next question asks, “What are the legal obligations to high-risk employees who, due to the nature of their jobs, cannot work remotely?”

Hanson: So the term high-risk employees is kind of charged. So I want to break that down a little. I think under the framework and looking at these issues, we have created the terminology called vulnerable populations, and if an employee falls into a vulnerable population, I think you need to determine and they’re asking for some sort of change to their job. So a job modification. I think you need to engage in the interactive process to determine number one, is this an employee with a disability. So being in a vulnerable population over the age of 65 is not going to be a disability. However, those individuals who may be fighting cancer or have other types of medical issues that would qualify for disabilities, you may need to reasonably act accommodate.

So I think that’s important in terms of the first step, identifying within the vulnerable populations of individuals, where do they fall, having an interactive dialogue with that employee to determine whether or not reasonable accommodations can be made, and look at what job modifications could occur. So, some jobs have to be done on campus. I understand that. But are there modifications in order to create a safe atmosphere?

So, if let’s say we have a custodial worker, and we’re going to have mitigation efforts, including PPE and other mitigation efforts and, in addition, maybe change their time in which they’re going to be on campus so that they’re not going to be with other people, or there’s going to be social distancing. Think about those things as you look at possible job modifications. Then finally, if that doesn’t work, and they simply cannot fulfill their job, then you, I think, need to look at what leave options they may have as well.

OSHA put out a statement that is really important. OSHA said a generalized fear of COVID does not excuse absences from work. So, we need to keep all of that in mind as we’re doing an analysis, and I really recommend institutions engage in that interactive process and that there’s documentation of the analysis of that process as well.

Bennett: Our final question for this Q&A: “What happens if we are in person and a student or teacher gets sick? Does the entire class immediately go remote?”

Hanson: Melanie, that’s a great question. I think the answer is, the famous lawyer answer, it depends. If you’ve put protocols in place in which you have masks in the classroom, in which you have social distancing within the classroom, in which you have other types of protections within the classroom, your answer may be different than if you don’t have those protections within the classroom or if there’s people that are not following those requirements within the classroom.

So I think it really does depend on that particular classroom and the exposure that could have happened during that class. So I would think about that very scenario in your plan to determine what you’re going to do and again, in your planning, if you’re following all the protocols for social distancing, for wearing masks, for doing all of the handwashing and using the hand sanitizer, you may not automatically go straight online. You may have some other options. But if you’re not doing some of those things, I think you probably will have to consider whether it’s the best option for you to go online with that entire class.

Bennett: Thank you to our participants for those questions. We’ll have a final extended Q&A in just a few minutes. But first, I’d like to tell you about some of UE’s recommendations and new resources about resuming on-campus operations. UE recently released our Guide to Resuming On-Campus Operations, which is available in the resources section of this webinar. It begins with some foundational issues that all institutions should consider, as they think about resuming on-campus operations.

So schools considering whether to start a resumption process should first review the gating section with key health and safety and containment and surveillance questions. After going through the gating questions and considering the foundational issues, if your school is considering resuming, move to the next section.

In the second half of the guide, we provide practical considerations to increase the safety of school operations. Those include many of the recommendations that we’ve discussed today during this webinar. UE’s COVID-19 resources, including the guide, are publicly available at The webpage includes our new resources for resuming on-campus operations, our FAQs, webinars, and links to our K-12 and higher ed resources.

We also received several questions requesting a UE COVID-19 prevention course. So I want to let you know we do have a COVID-19 course coming soon. You can watch our website, this COVID page in our newsletters, for more information about that course.

Now let’s move into our final Q&A. Jean, the first question is for you: “Have you seen any instructional guides on how to properly take temperature, wash hands, clean office areas, that you can recommend?”

Chin: Thank you, Melanie and as chair of the COVID Task Force, I have been seeing so many instructional guides and videos, it would make your head spin. I’ve seen great ones from SafeColleges, and they’re at a website called Johns Hopkins has great ones, the WHO, and, of course, CDC has good instructions on all of those things. So those four sources should do you well.

Bennett: Thanks, Jean. Hayley, the next question is for you: “Should schools allow all employees the option to continue remote work, even if they’re not at high risk for COVID-19?”

Hanson: Well, I think this answer really depends on several things. Number one, I think you need to assess if employees are making a request for an accommodation if they have a disability under the ADA. So you need to run that through your normal course to determine whether or not this individual has a disability and whether or not an appropriate accommodation would be to be able to work from home. If they don’t fall into the category in which they have a disability, I think the institution needs to determine on a policy basis how it will handle individual requests when they are not in a high-risk category.

I think there’s two other categories that you need to kind of think about, that the employee themself is in a higher risk category, is one. The second is that the employee has family that they’re living with who may be in a high-risk category and are concerned about going to campus and bringing that home. Then the third is just the mental health, anxiety, or other types of issues or depression that may occur with these employees, and whether or not they’re asking for accommodations based on some mental health issues that they are dealing with.

I also think from an employment perspective, you’ve got to determine whether or not it is a reasonable accommodation for that particular job, as well as you’re making these assessments. Of course, that’s going to be individualized and you’re going to want to make sure you document your decision.

Bennett: Thanks, Hayley. Jean, the next question’s for you: “If students and teachers are masked, can they be less than 6 feet apart?”

Chin: Melanie, I’m going to answer that, like Hayley just answered hers. It depends. So there’s really very few hard yes or hard no answers when it comes to COVID. Everything is about risk reduction. So the greatest risk is people who come from all corners of the states or the world get tightly packed in for prolonged periods of time and have no masks. If you’re 3 feet apart, it’s less risky. If you’re 6 feet apart, it’s even better. If you have no mask on, it’s high risk. If you have a mask on and remain 6 feet apart, well, your risk is lower. So the answer, which doesn’t really answer the hard question, the less amount of time the contact, the better, being outside, better, wearing a mask, better. I hope that helps.

Bennett: That is helpful. Thank you. The next question is actually for both of you, but I’m going to pose it to Hayley first: “Under what circumstances should schools close again during the upcoming school year?”

Hanson: I’m sorry to say this again, but I think it’s really going to depend on the circumstances that are happening at that institution, number one, and the rate of infection that they’re dealing with, and then number two, what’s happening in their particular local municipality or even state in terms of making those decisions. So I know that there are plans. I think all schools understand that there are going to be students who test positive for COVID-19 and employees as we return to campus, but understanding maybe where those triggers will be to make these hard decisions. I’m not sure that anyone could predict right now where that line is going to be. But Jean, I will ask you to comment on this question as well and give us your thoughts.

Chin: Well, thanks, Hayley. This is probably one of the most asked questions I’ve received lately: What’s the threshold to close. Everybody wants to know that. And like you said, it’s dependent upon what’s happening on your campus. Are you having loads of COVID-19 transmission on campus at a greater rate than the local community, or the opposite? Are you having loads of transmission happening in community as compared to campus because it’s a leaky area, campus is going to leak right out into the community.

Another thing that you might think about is that there’s evidence of the institution disregarding the physical distancing and the PPE requirements, like we were just talking about before. You’re absolutely right, Hayley, what’s happening in the community and what’s happening on campus.

Bennett: Jean, I’m actually going to stay with you: “When making our resumption plans, how long should we assume the pandemic will last?”

Chin: That’s another crystal ball question. You guys are always asking the hard ones. Most are thinking at least through next spring, and that’s why there’s great, great anticipation of this safe, effective, widely available vaccine or some kind of treatment. Until then, we are going to be living in this new normal for a long time. And I think Dr. Fauci is talking about that today at the Senate.

Bennett: That’s what I heard as well. Hayley, I actually have a Clery Act question for you: “Does the Clery Act require that schools send out an alert to their campus community when there’s a positive case of COVID, either employee or student?”

Hanson: According to the Department of Education guidance on this issue, a university is not required to give regular ongoing updates on COVID-19 or proactively identify positive COVID-19 cases within the campus community. Nor does the department interpret the Clery Act to apply to a positive COVID-19 case among individuals who are not attending classes, working, or residing on campus. The department has stated that an institution can satisfy their emergency notification provisions by creating a banner at the top of the institution’s homepage containing information about COVID-19 and necessary health and safety precautions, as well as encouraging them to obtain information from health care providers, state and local authorities, and the CDC.

So we do recommend that each campus create this banner and create a landing page for COVID-19-related information, not only to satisfy Clery and to assist in making sure that the campus is well-informed, but also as a place to be putting out your plan, and that individuals who need assistance would be able to easily click on your website and know where to go to get helpful resources.

Bennett: Thank you. Jean, when you were talking about dorms earlier, you mentioned that schools should try to go for single occupancy of rooms, but this participant asks if schools choose to implement double occupancy in some residence hall rooms, what additional safety considerations they should put in place?

Chin: Well, some of the things, Melanie, that the residence hall folks are doing, they’re trying to ensure at least 6 feet of distance in the sleeping situations. If they can’t do, that some are installing barriers like Plexiglas if they can, if not, they’re doing curtains around the beds, like shower curtains or just your regular cloth curtains. They’re reconfiguring the room so that students are sleeping head to foot, which is funny. We originally picked that up from CDC guidance for detention centers or jails, and for some reason that amused me, I don’t know why. But people sleeping head to foot was another solution.

Students in the room with their roommates don’t need to wear masks, because they’re going to be considered a family unit. But they still need to adhere to those other solid prevention practices, like cleaning and disinfecting.

Bennett: That’s helpful to know that students within the same room are essentially considered a family unit at that point. Going to Hayley: “What should schools keep in mind when they require employees to disclose their COVID-19 diagnosis or that of a household member?”

Hanson: So I would remind you that, again, this is the notification of a positive diagnosis, not antibodies, and not whether or not you’ve had antibody testing for employees. I think there’s a distinction there that you need to be careful of, and then making sure that you are meeting all of the requirements for keeping that information confidential, but then being able to contact trace if that employee has been on campus for others who need to know or need to be aware that they could have been exposed. So those are some of the things I think you should keep in mind.

Bennett: Thanks. Jean, we’re going to talk about residence halls again, residence halls again. What are the best practices for residence hall moving days?

Chin: ACUHO-I, which is our housing partner, who helped us write some of those guidelines for ACHA, they developed a whole set of recommendations. And it included some of the moving guidance. And moving days, they are not going to look the same like they have in the past. So some things that they recommended, Melanie, they recommended including an extended schedule to accommodate the number of people needing to move in before classes.

So instead of, say, four days, they’re going to have eight days, or two days, they’re going to have four days. They’re going to limit the number of individual helpers per resident for moving. I know UGA is definitely doing that. Consider a phased move in process that allows for check-in to happen in some areas and that allows for physical distancing and whether keys or access can be given ahead of time.

They’re going to limit volunteers who actually used to do hands-on work and instead, they’re just going to be given directional assistance. Then they’re reconsidering whether or not to use the big moving bins, because those are going to have to be cleaned and disinfected.

Bennett: That’s helpful to keep in mind. The final question I’m going to pose to both of you. I’ll go to Jean first this time: “Other than those already discussed, have you seen any resuming on-campus operations resources that you can recommend?”

Chin: I think one that we recently discovered that has just been put out maybe two weeks ago, Melanie and Hayley, Johns Hopkins put out a 96-page guide. And it’s called COVID-19 Planning Guide and Self-Assessment for Higher Ed. It’s really quite good and gives you a checklist and some of those threshold questions that some earlier person asked about and that can be found at

Hanson: So I would just add that there’s some really good resources when it comes to return to sport because a lot of people are asking about how are we going to handle athletics as we return to campus. And the US Council for Athletes’ Health has put out a really good comprehensive document about return to sport and a checklist about things that you should be thinking of as you’re having student-athletes come back and resume their competitive activities. So I think that’s a very good resource as well that we haven’t talked about yet.

Bennett: Wonderful, and hopefully we’ll be able to put these up on the resources when we put the webinar online, the recording. So, that ends our webinar. I want to thank Jean Chin and Hayley Hanson for participating in this webinar. We hope you found the program helpful. Remember, the audio recording and slide deck will be posted soon on EduRisk Solutions. That concludes the webinar, and you may now disconnect.