News & Insight

HMBR Resource for Colleges and Universities Considering Reopening for Fall 2020

As students across the nation wrap up an unconventional semester, college and university leadership and administrators are wondering when their campuses can reopen and how they might begin this herculean task. While much remains uncertain, it is clear that colleges and universities must be nimble in meeting this challenge while keeping their community’s health and safety at the forefront of their decision-making.

To assist our clients in their risk assessment, we have compiled points of consideration, suggested timelines and potential community stakeholders for accomplishing this coordinated effort. These considerations must, of course, be consistent with CDC guidance and state and local directives. While these considerations serve as a starting point for analysis, this resource does not identify all potential considerations and risks. For many of these considerations, community stakeholders may also want to seek external expertise and guidance in areas such as regulatory compliance, accounting or health services. Last, this resource presumes a campus with commuter and residential students, as well as a presumption that a vaccine for COVID-19 is not available by Fall 2020.

General

Considerations

Timeline

Community Stakeholders[1]

Form COVID-19 Reopening Committee and establish schedule of meetings leading up to reopening, as well as throughout Fall 2020

 

– Identify committee members based on community stakeholders with necessary input by June 2020

– Establish meeting schedule by June 2020

President, General Counsel, Finance Officers, Office of the Provost, Campus Safety & Security, Student Health Services, Student Services, Athletic Director, Student Representatives

 

Adjustments to academic calendar for Fall 2020:

– Stagger arrival back to campus so as to satisfy social distancing requirements

– Extend class schedules into Saturday or Sunday so as to condense semester and minimize students’ overall time spent on-campus

– Cancellation of Fall Break and use of distance learning following Thanksgiving Break

– Meet with stakeholders as early as possible to determine necessary adjustments to academic calendar for Fall 2020

 

 

 

 

Office of the Provost, Academic Department Chairs, Dean of Students, COVID-19 Reopening Committee

 

 

 

 

Availability of budget and workforce for implementation of COVID-19 response:

– Access CARES Act appropriations

– Visit HMBR’s blog post on best practices for accounting and disbursing allocations from the Higher Education Emergency Relief Fund

– Meet with stakeholders as early as possible to determine likelihood of successful reopening for Fall 2020 based on available budgetary and workforce resources

 

 

 

President, General Counsel, Human Resources, Finance Officers, COVID-19 Reopening Committee

 

 

 

Availability of health screening supplies and testing:

– Personal Protective Equipment (“PPE”)

– COVID-19/antibody testing

– Temperature screening devices

– Cleaning supplies and hand sanitizer

– Acquire supplies and testing as needed for campus population and facilities prior to reopening for Fall 2020

– Schedule weekly meetings to discuss progress of acquisitions and/or depletion of reserve supplies

COVID-19 Reopening Committee, Facilities Management, Finance Officers, Student Health Services

Communications with campus community (students, parents, faculty and staff):

– New procedures and protocols implemented with each phase of reopening

– New training requirements on campus procedures and protocols regarding COVID-19

– Type and frequency of communications (email, text, website and/or hotline)

– Reference to additional resources as relevant (CDC guidance, state and local orders, etc.)

– Establish timeline for each communication

– Develop online training materials and require completion of training prior to student, faculty and staff return to campus

President, Office of Communications, Campus Safety & Security, IT Support, COVID-19 Reopening Committee

Develop response plan in the instance of second or third wave of COVID-19 or increase in infection upon reopening campus

– Assess risk of remaining opening based on the best available public health information from federal, state and local agencies

President, General Counsel’s Office, Finance Officers, Campus Safety & Security, Student Health, Athletic Director, Student Representatives

 

COVID-19 Testing, Temperature Screening and Provision of PPE

Considerations

Timeline

Community Stakeholders

Require students, faculty and staff to submit proof of COVID-19/antibody testing prior to return to campus[2]

– Communicate as a condition for student, faculty and staff arrival back to campus, similar to proof of certain vaccination requirements for incoming students

Student Health, Human Resources

Administer COVID-19/antibody testing for students, faculty and staff at intervals recommended by medical practitioners

– Communicate as a condition for student, faculty and staff arrival back to campus

Student Health, Human Resources

Provision of masks and gloves to students, faculty and staff; masks must be required at all times when outside dorm rooms

– Supply and replenish on a regular basis

Facilities Management, Residential Education and Dining Services; Campus Safety and Security

Provision of sanitizers in all buildings and dorm facilities

– Supply and replenish on a regular basis

Facilities Management, Residential Education and Dining Services

Prepare student health facilities on campus to receive COVID-19 patients or establish protocols for transferring COVID-19 patients to local hospital systems

– Train staff prior to reopening

Student Health

Encourage flu shots, unless it is medically not advisable, so that health care providers do not have to contend with flu outbreak in addition to COVID-19 in the Fall/Winter

– Communicate requirement with students, faculty and staff prior to their arrival back on campus

Student Health, Human Resources

Require temperature checks outside every building on campus

– Communicate as a condition for student, faculty and staff arrival back to campus

Campus Safety and Security, Human Resources

Develop and implement policies for telemedicine visits when appropriate, particularly for students with immune-compromised conditions, and update screening forms to include COVID-19 symptoms

– Train staff prior to reopening

Student Health

 

Academic and Student Issues

Considerations

Timeline

Community Stakeholders

Require socially distanced seating in classes with over 10 people; alternate attendance by teleconference or in-person on a weekly basis.

– Communicate requirement with students and faculty as condition to academic participation prior to their arrival back on campus

– To the extent permitted by applicable law, require students and faculty to acknowledge assumption of risk prior to participation

Office of the Provost, Department Chairs, Dean of Students, Facilities Management

Determine methods of instruction for clinical-based, lab-based and/or performance-based courses consistent with accreditor requirements, if applicable

– Communicate requirement with students and faculty as condition to academic participation prior to their arrival back on campus

– To the extent permitted by applicable law, require students and faculty to acknowledge assumption of risk prior to participation

Office of the Provost, Department Chairs

Only allow students who are not immune-compromised the option of attending in-person classes and other campus events

– Communicate requirement with students and faculty as condition to academic participation prior to their arrival back on campus

– To the extent permitted by applicable law, require students and faculty to acknowledge assumption of risk prior to participation

Office of the Provost, Dean of Students

Require all classes, regardless of class size, to be simulcast online in case a student tests positive with the temperature check

– Communicate requirement with students, faculty and staff prior to their arrival back on campus

Office of the Provost, Department Chairs, Dean of Students

Develop flexible attendance policies that support students who become ill and/or who must quarantine

– Communicate policy with students and faculty prior to their arrival back on campus

Office of the Provost, Department Chairs, Dean of Students

Allow immune-compromised faculty and/or underlying conditions, as well as faculty over 55 (or an age set by medical professionals) the option of teaching remotely.  In such cases, classes can feature a TA in the classroom.

– Communicate option with faculty prior to their arrival back on campus

– To the extent permitted by applicable law, require immune-compromised faculty, faculty with underlying conditions, and faculty over 55 (or an age set by medical professionals) to acknowledge assumption of risk when declining the option of teaching remotely

Office of the Provost, Department Chairs, Human Resources

Limit  in-person office hours so that they are by appointment only and/or by teleconference only

– Communicate requirement with students and faculty prior to their arrival back on campus

Office of the Provost, Department Chairs, Dean of Students

To the extent consistent with medical guidance and consistent with civil rights guidance, consider establishing dormitories based on students’ exposure to COVID-19[3]:

– Dorm for students who have tested positive for COVID-19/antibodies;

– Dorm for students who have immune-compromised or underlying conditions;

– Dorm for students who have tested positive for COVID-19, which will serve as an area for quarantine and will allow students to receive medical monitoring, delivered meals, remote academic learning and mental health support

– Communicate requirement with students as condition to academic participation prior to their arrival back on campus

– To the extent permitted by applicable law, require students to acknowledge assumption of risk prior to participation

– Dorms designated for students in quarantine should be known to campus staff on an as-needed basis

Dean of Students, Student Health, Facilities Management, Residential Education and Dining Services

Install Plexiglas partitions to separate students and faculty in smaller classrooms

– Communicate implementation with students and faculty prior to their arrival back on campus

Facilities Management

Provide online registration and class scheduling

– Communicate implementation with students prior to their arrival back on campus

Dean of Students, Registrar Office

Provide academic and financial aid advisement by teleconference

– Communicate implementation with students and staff prior to their arrival back on campus

Dean of Students, Office of the Provost, Department Chairs, Financial Aid

Equip Title IX Coordinator, ADA/Section 504 Coordinator and Equity Office with necessary remote tools and other resources for continued compliance with federal civil rights laws

– Implement new Title IX regulations prior to August 14, 2020

– Visit HMBR’s blog post for a comprehensive summary of the new Title IX regulations and for additional resources on implementation

-Evaluate accommodations requests on a case-by-case basis using interactive process

General Counsel, Title IX Coordinator, Equity Office, Dean of Students, Human Resources

Identify disciplinary measures that may be taken in instances where students violate social distancing requirements or other COVID-19 policies and protocols

– Provide notice to student, faculty and staff about updated policies as necessary

Dean of Students, Human Resources

 

Facilities Issues and Maintenance

Considerations

Timeline

Community Stakeholders

Arrange points of egress to enable social distancing; designate doors as “in” and “out” and assign students to specific “in” doors (where there will be lines due to temperature checks/administrating of tests)

– Install appropriate signage and communicate requirement to students, faculty and staff prior to reopening campus

Facilities Management; Campus Safety and Security

Set maximum numbers of people allowed on an academic building floor at one time – so no more than an appropriate number of classes are scheduled on the same floor at one time 

– Install appropriate signage and communicate requirement to students, faculty and staff prior to reopening campus

Office of the Provost, Department Chairs, Dean of Students, Facilities Management; Campus Safety and Security

Establish designated exits and entrances to reduce the number of people at any point of egress

 

– Install appropriate signage and communicate requirement to students, faculty and staff prior to reopening campus

Facilities Management; Campus Safety and Security

Consider using atomizers to disburse non-toxic disinfectants

– Determine appropriate use prior to reopening campus

Facilities Management

Consider using FDA-approved, HOCL-based products that are safe for consumption in HVAC systems, atomizers and/or in nebulizers administered to students, faculty and staff

 

– Determine appropriate use prior to reopening campus

Facilities Management

Install Plexiglas partitions to separate students from administrators in various offices where remote service is not advisable

 

– Install prior to reopening campus

Facilities Management

Revise cleaning and disinfection schedules and procedures for all common and high traffic areas and implement use of HOCL (Hypochlorous acid)-based cleaning products[4]

– Develop procedures and establish protocols prior to reopening campus

Facilities Management

Prepare facilities for social distancing:

– Install signage at entrances and along pathways to indicate social distancing requirements

– Remove chairs and desks to ensure appropriate social distancing

– Remove high-touch items and replace with single-use items

– Post maximum occupancy signage

– Implement prior to reopening campus

COVID-19 Reopening Committee, Facilities Management

 

 

Employees Issues

 

Considerations

Timeline

Community Stakeholders

 

Categorize employees based on whether they need to be on campus to perform their jobs and allow those that can work remotely to do so

-Categorization will likely be consistent with Spring 2020 determinations

– Communicate changes to employee classifications as necessary

 

Human Resources

 

Stagger employee shifts to reduce the number of people in the workplace at the same time

– Communicate employee schedules as available, ideally on a monthly basis

Human Resources, Staff Managers/Supervisors

 

Train employees on procedures for preventing COVID-19 infection and require face coverings during shifts

– Develop online training materials and require completion of training prior to return to campus

Human Resources, Staff Managers/Supervisors

 

 

 

 

Equip Title IX Coordinator, ADA/Section 504 Coordinator and Equity Office with necessary remote tools and other resources for continued compliance with federal civil rights laws

 

-Implement new Title IX regulations prior to August 14, 2020

-Evaluate accommodations requests on a case-by-case basis using interactive process

General Counsel, Title IX Coordinator, Equity Office, Dean of Students, Human Resources

 

 

 

Athletics and Campus Events

Considerations

Timeline

Community Stakeholders

Assess the potential for COVID-19 transmission in each sport:

– Close contact sports include wrestling, football, basketball and other contact sports

– Minimal contact sports include golf, singles tennis and fencing

– Consider the risk of transfer through athletic equipment (basketball, volleyball, baseball) or aerosolization during high-intensity workouts

– Meet with stakeholders as early as possible to determine possibility of athletic and campus events prior to Fall 2020

Athletic Director, Athletic Coaches, Student Health, Team Physicians, Student Athlete Representatives

Administer COVID-19/antibody testing and temperature screening for student athletes either prior to games/competitions or at intervals recommended by medical practitioners; ensure appropriate PPE on-hand at all times

– Communicate procedure to student athletes as condition to participation

– To the extent permitted by applicable law, require students to acknowledge assumption of risk prior to participation

Athletic Director; Athletic Coaches, Student Health, Team Physicians

Implement social distancing protocols in athletics training and weight rooms, locker rooms, team meeting rooms, fitness and wellness classes and other high volume area

– Communicate procedure to student athletes as condition to participation

– To the extent permitted by applicable law, require students to acknowledge assumption of risk prior to participation

Athletic Director, Athletic Coaches, Student Health

Follow public health recommendations of federal, state, local and sports governing bodies related to travel for student athletes and intramural sports

– Keep students appraised of public health recommendations as-needed

Athletic Director, Athletic Coaches, Student Health

Require temperature testing for large campus community events (sports and rallies) even if outdoors

– Communicate requirement to students, faculty, staff and other attendees prior to event

Campus Safety and Security, Facilities Management

Hold outdoor events in places with restricted access points to facilitate orderly temperature testing 

– Install appropriate signage and communicate requirement to students, faculty, staff and other attendees prior to event

Campus Safety and Security, Facilities Management

Observe social distancing by reducing capacity for campus community events:

– Establish lottery-based ticket system for attending in-person events

– Communicate details to students, faculty, staff and other attendees prior to event

COVID-19 Reopening Committee; Athletic Director; Student Union

Substitute in-person attendance with televised or live streaming options

 

– Communicate remote viewing options to students, faculty, staff and other attendees prior to event

COVID-19 Reopening Committee; Athletic Director; Student Union

We realize that some individuals may feel there is an unsurmountable amount of work to be done when confronted with all that must be considered and accomplished between now and the start of the Fall 2020 semester to reopen campus. HMBR is available to help. Please reach out to our Higher Education Team at (312) 946-1800 for assistance with policy development, risk assessments, implementation strategies and other issues related to COVID-19.

[1] Colleges and universities should identify community stakeholders who can provide valuable input and serve as operational owners based on their institution’s individual needs and resources.

[2]  At present, antibody testing lacks adequate evaluation of efficacy and reliability according to the American College Health Association and is inadequate to determine whether a positive test conveys immunity. The inclusion of antibody testing in this analysis presumes scientific improvement in evaluating and determining immunity.

[3] In all instances, single residency for dorm rooms and bathrooms are ideal when possible.

[4] In all instances, custodial workers should be provided appropriate PPE and training consistent with their duties.

  May 26, 2020  |  By    |   On COVID-19 and Cares Act (EDUCATION)