The State Issues Guidance for the Reopening of Schools and School-Based Programs, Childcare Facilities and Day Camps

On June 5, 2020, the State issued industry guidance for schools and school-based programs, childcare facilities, and day camps.

COVID-19 Industry Guidance for Schools and School-Based Programs

The Governor previously announced that counties that have completed and submitted a written attestation to the California Department of Public Health (CDPH) indicating the county had met specific readiness criteria could move more quickly through the reopening process.  The Governor stated that counties approved to move more quickly through the reopening process could reopen schools after the state issued guidance, and if consistent with local officials and orders.  The long awaited state guidance, titled, “COVID-19 Industry Guidance: Schools and School-Based Programs” (School Guidance), was released on June 5^th.  The preface to the School Guidance notes that it is interim guidance, and will be updated as new data and practices emerge.  Additional guidance is forthcoming on school-based sports and extracurricular activities.

The School Guidance has a recommended effective date of no sooner than June 12^th, but should be implemented only with county health officer approval.   We note that many Bay Area counties have not been approved to move more quickly through the reopening process, including San Francisco, Alameda, Santa Clara, Contra Costa, Marin, and San Mateo counties.   Further, the majority of county and local stay at home orders do not permit schools to reopen at this time for in-person classroom instruction.

The School Guidance, which is 14 pages, contains interim guidelines and considerations intended to help schools plan and prepare to resume in-person instruction.   Some of the highlights included in the School Guidance are the following considerations and recommended measures:

1.  General Measures

• • Preliminary conditions, such as reviewing relevant county variance documentation, consulting with local health officials, and regularly reviewing updated guidance from State agencies, considering Cal/OSHA guidance, and developing plans for possible school closures due to COVID-19.

2.  Promoting Healthy Hygiene Practices

1. • Using portable handwashing stations throughout a school and near classrooms to minimize movement and congregations in bathrooms to the extent practicable.
   • Developing routines enabling students and staff to regularly wash their hands at staggered intervals.
   • All staff should use cloth face coverings unless Cal/OSHA standards require respiratory protection. Teachers can use face shields, if available, which enable younger students to see their teachers’ faces and to avoid potential barriers to phonological instruction.
   • Students should be encouraged to use cloth face coverings.
   • Schools should provide and ensure staff use face coverings and all required protective equipment.
   • Food service workers and staff in routine contact with the public (e.g., front office) should use gloves in addition to facial coverings.

3.  Intensifying Cleaning, Disinfection, and Ventilation

1. • Cleaning and disinfecting protocols for frequently touched surfaces, shared equipment, and indoor and outdoor spaces as well as recommended selection criteria for cleaning products.
   • Staff should clean and disinfect frequently touched surfaces within school and on school buses at least daily and, as practicable, frequently throughout the day by trained custodial staff.
   • Limit use of shared playground equipment in favor of physical activities that require less contact with surfaces.

4.  Implementing Distancing Inside and Outside the Classroom

• • Stagger arrival and drop off-times and locations as consistently as practicable as to minimize scheduling challenges for families.
  • Designate routes for entry and exit, using as many entrances as feasible. Put in place other protocols to limit direct contact with others as much as practicable.
  • Students should remain in the same space and in groups as small and consistent as practicable. The same students should be kept together with the same teacher or staff, to the greatest extent practicable. Consider ways to keep teachers with one group of students for the whole day.
  • Maximize space between seating and desks. Distance teacher and other staff desks at least six feet away from student desks. Consider ways to establish separation of students through other means if practicable, such as, six feet between desks, partitions between desks, markings on classroom floors to promote distancing or arranging desks in a way that minimizes face-to-face contact.
  • Minimize congregate movement through hallways as much as practicable. For example, establish more ways to enter and exit a campus, and staggered passing times when necessary or when students cannot stay in one room.
  • Serve meals in classrooms or outdoors instead of cafeterias or group dining rooms where practicable. Serve individually plated or bagged meals. Avoid sharing of food and utensils and buffet or family-style meals.
  • Consider holding recess activities in separated areas designated by class.

5.  Limit Sharing

1. • Minimizing sharing of supplies among students and clean and disinfecting supplies between use.

6.  Training All Staff and Families

1. • Conducting virtual training of staff and families on enhanced sanitation practices, physical distancing guidelines and their importance, proper use, removal, and washing of cloth face coverings, screening practices, and COVID-19 specific exclusion criteria.

7.  Checking for Signs and Symptoms

1. • Implementing screening procedures of all staff and students before they enter the facility, including visual checks, temperature checks, and symptom and exposure screening.
   • Screening should include taking students’ temperature with a no-touch thermometer, and asking all individuals about COVID-19 symptoms within the last 24 hours and whether anyone in their home has had COVID-19 symptoms or a positive test.
   • Adopt policies that do not penalize students and families when a student misses class.

8.  Planning for When a Staff Member, Child or Visitor Becomes Sick

1. • Isolating and seeking medical care for students or staff exhibiting symptoms of COVID-19, notifying local health officials, staff, and families of positive cases of COVID-19 while maintaining confidentiality.

9.  Maintaining Healthy Operations

1. • Monitor staff absenteeism and have a roster of trained back-up staff where available, designate a staff member responsible for COVID-19 related communications, and maintain communication systems that allow staff and families to self-report symptoms.
   • Support staff and students who are at higher risk for severe illness or who cannot safely distance from household contacts at higher risk, by providing options such as telework, virtual learning or independent study.

10.  Considerations for Partial or Total Closures

1. • After a student or staff member tests positive for COVID-19 and exposes others at school, consult with the local public health department, consider temporary closure, clean and disinfect the school campus, and communicate with students, parents, staff, and the community.

In planning for resuming in-person instruction, we recommend that schools review the state’s interim School Guidance, county and other local orders and guidelines, as well as the Centers for Disease Control (CDC) guidance and resources for the reopening of schools, which is available here.   LCW will be offering a return to school policy toolkit and webinar on June 19th, which will include policies recommended by the state interim guidance.

Several counties have issued guidance or planning recommendations on the reopening of schools, including Los Angeles County, San Diego County, Sacramento County, and Marin County.

COVID-19 Industry Guidance for Childcare Programs and Providers

The COVID-19 Industry Guidance for Childcare Programs and Providers (Childcare Guidance) was developed in collaboration between the California Department of Social Services and the California Department of Education.  However, childcare programs and providers may only open if permitted to do so by the local health order in place where they are located and must also operate according to any orders, modifications, or requirements issued by their local public health authorities.

Childcare facilities must also comply with the guidance for childcare facilities released by the State Department of Social Services on April 7, 2020.

The Childcare Guidance outlines modifications and requirements concerning planning, cleaning, hygiene, arrival procedures, health screening, group size and staffing, classroom space and physical distancing, and meal times.  For example, under the Childcare Guidance, staff must wear cloth face coverings and—when serving food, handling trash, or using cleaning and disinfectant products—they must also wear gloves.  In addition, providers must implement daily symptom and temperature screening of children and send children home if they develop symptoms; keep children in small, consistent groups; keep children six feet apart during meals and naps; and increase outdoor activities.  The Childcare Guidance also provides information on coronavirus symptoms and additional resources for childcare facilities.

However, childcare programs and providers should be aware that the guidance from their local public health authorities might be more restrictive than the State Childcare Guidance.

For additional information on considerations for the reopening of childcare facilities, see the LCW Special Bulletin titled, “Further Guidance on the Reopening of Childcare Facilities,” issued on May 26, 2020.

COVID-19 Industry Guidance for Day Camps

The COVID-19 Industry Guidance for Day Camps (Day Camp Guidance) is effective no sooner than June 12, 2020.  However, the issuance of the Day Camp Guidance does not mean that day camp programs may open statewide on June 12, 2020.  A day camp program cannot open unless the local health order in place where the day camp program is located permits day camps to open.  Even then, day camps must operate in accordance with any local orders or guidance applicable to day camps in addition to the Day Camp Guidance.

The State also recommends that day camp programs implement and make decisions about the recommendations in the Day Camp Guidance “in collaboration with local health officials and other authorities.”  The State further recommends implementing the guidance by tailoring it for each setting, by training and supporting staff, and by adequately considering camper and family needs.  The State has not issued guidance for overnight camps yet, but noted that it “is forthcoming.”

The Day Camp Guidance includes recommendations in ten areas.  Here are some highlights:

1.  General Measures

• • Preliminary conditions, such as reviewing relevant county variance documentation, consulting with local health officials, and regularly reviewing updated guidance from State agencies, considering Cal/OSHA guidance, and developing plans for possible day camp closures due to COVID-19.

2.  Promoting Healthy Hygiene Practices

• • Use of cloth face coverings, hand washing practices, and other healthy hygiene practices among staff and campers.

3.  Intensifying Cleaning, Disinfection, and Ventilation

• • Cleaning and disinfecting protocols for frequently touched surfaces, shared equipment, and indoor and outdoor spaces as well as recommended selection criteria for cleaning products.

4.  Implementing Distancing

• • Protocols for implementing physical and social distancing among staff, campers, and families at arrival and departure, in recreational spaces, during recreational activities, and during meals.

5. Limiting Sharing

• • Minimizing sharing of supplies among campers and cleaning and disinfecting supplies between use.

6.  Training All Staff and Families

• • Conducting virtual training of staff and families on enhanced sanitation practices, physical distancing guidelines and their importance, proper use, removal, and washing of cloth face coverings, screening practices, and COVID-19 specific exclusion criteria.

7. Checking for Signs and Symptoms

• • Implementing screening procedures of all staff and campers before they enter the facility, including visual checks, temperature checks, and symptom and exposure screening.

8. Planning for When a Staff Member, Child, or Visitor Becomes Sick

• • Isolating and seeking medical care for campers or staff exhibiting symptoms of COVID-19, notifying local health officials, staff, and families of positive cases of COVID-19 while maintaining confidentiality, and cleaning and disinfecting areas used by any sick person.

9.  Maintaining Healthy Operations

• • Monitor staff absenteeism and have a roster of trained back-up staff where available, designate a staff member responsible for COVID-19 related communications, and maintain communication systems that allow staff and families to self-report symptoms.

10.  Considerations for Partial or Total Closures

• • After a camper or staff member tests positive for COVID-19 and exposes others at camp, consult with the local public health department, consider temporary closure, clean and disinfect the camp facility, and communicate with campers, parents, staff, and the community.

For additional information on considerations for the reopening of day camps, see the LCW Special Bulletin titled, California Counties, CDC, and ACA Begin Issuing Guidance for Opening of Summer Camps, issued on May 29, 2020.

Requirements for Schools, Childcare Programs and Providers, and Day Camps

We note, as discussed in this Bulletin, the fact that the State has issued industry guidance does not mean that schools can resume in-person instruction at this time or operate childcare and day camp programs for all students.   Schools must carefully review their local orders.

In addition, before reopening, schools, childcare programs and providers, and day camps must:

1. Perform a detailed risk assessment and create a site-specific protection plan
2. Train employees on how to limit the spread of COVID-19. This includes how to screen themselves for symptoms and when to stay home.
3. Set up individual control measures and screenings
4. Put disinfection protocols in place
5. Establish physical distancing guidelines