As the academic year begins to wind down, independent schools are looking toward the fall and beginning to plan for the 2021-2022 school year. As they did last year, they are paying particular attention to the COVID-19 health and safety protocols that will be in place. Independent schools are looking at a different landscape this year than they were in 2020 – with the availability of the vaccine, certain federal, state, and local health and safety guidelines are being lifted or otherwise modified. Schools would be wise to consider the following as they develop their plans for the fall:
- Policies on Vaccination: As discussed here, schools are permitted to require that their employees and students be fully vaccinated for COVID-19. While some schools have already made the decision to require their employees and students to be vaccinated, some schools are still grappling with the decision. Where all or a portion of the community may be eligible to be vaccinated, adopting a mandatory vaccination policy can go a long way in curbing the spread of COVID-19 and creating a healthy and safe learning and working environment for all. In many ways, the decision of whether to have a mandatory vaccination policy will, in large part, inform the rest of your school's policies and protocols for the 2021-2022 school year, as we now have guidance differentiating requirements for issues like mask wearing and quarantine after exposure based on a person's vaccination status. Schools considering whether to adopt a vaccination requirement would be well advised to remember that a portion of their community may not be eligible to be vaccinated by the beginning of the school year, and therefore additional health and safety measures may continue to be in place.
- Mask Wearing: Consider whether and the extent to which your school's policy on mask wearing and other PPE will continue to be in effect. Depending on the age level of students whom the school serves and whether there is a vaccination policy in place, it is possible that there will still be unvaccinated individuals on campus. While guidance from the Centers for Disease Control and Prevention has stated that vaccinated individuals do not need to wear masks, unvaccinated individuals will still need to wear masks in many settings. Understanding whether your school will require eligible individuals to be vaccinated and putting in place protocols to confirm vaccination status will help ensure that it is able to enforce mask wearing requirements appropriately.
- COVID-19 Testing: Many schools also used routine COVID-19 testing as an additional safety protocol, to ensure that they were able to quickly identify and quarantine possible cases of COVID-19 in the community. Whether your school adopts a COVID-19 vaccination policy will, in large part, inform whether your school continues routine testing for COVID-19. Schools that have adopted mandatory COVID-19 vaccination policies for their employees and students may find themselves either moving away from COVID-19 testing entirely or reducing the frequency with which they test members of the community who are vaccinated. Schools that are not requiring COVID-19 vaccination for the general school population, or for groups of their community who are not eligible to be vaccinated, may consider keeping their COVID-19 testing program in place as a mitigation measure.
- Cohorting: Keeping certain groups of students together throughout the day in "cohorts" was a common health and safety measure that schools adopted over the past year. This allowed schools to achieve necessary social distancing and quickly identify potential "close contacts" in the event of a positive case of COVID-19 in a single cohort. Whether and the extent to which cohorting will need to remain in place will depend not only on federal, state, and local guidelines for social distancing, but also on the vaccination status of the student population and the school's vaccination policy, as the CDC has stated that vaccinated people do not need to maintain social distance or quarantine on exposure. While state and local guidelines may differ, vaccination will surely come into play as schools consider using cohorts in the fall.
Federal, state, and local guidelines may continue to evolve over the course of the summer. As with last year, schools should ensure that they are aware of any updated guidance and preserve their ability to modify their policies and protocols as needed. As always, schools would be wise to keep at the forefront of their planning their utmost responsibility – to ensure that they take measures to protect the health and safety of the students entrusted to their care.