CORONAVIRUS COVID-19: SPRING BREAK EDITION

March 6, 2020

By: Gail M. Norris

Spring break invites faculty travel to conferences abroad, student study trips abroad and student dispersal to their home locations. What should a higher education institution do to prepare for this period of increased travel?

1. COMMUNICATE, COMMUNICATE, COMMUNICATE. Members of your institution’s community will want up-to-date information about COVID-19 to stay informed about ways to stay healthy and safe. Misinformation and rumors can fill in for the absence of sound information.
2. Stay up to date. The information related to COVID-19 as a health risk in many areas is changing rapidly. There are a number of resources available to keep higher education institutions apprised. Notably, see CDC Interim Guidance for Administrators of US Institutions of Higher Education to Plan, Prepare and Respond to Coronavirus Disease 2019 (COVID-19). 
   Many colleges and universities have webpages dedicated to COVID-19 and include FAQs and other information that can help inform policies and response plans.
3. Prohibit institution-sponsored travel to CDC Level 3 countries (where CDC recommends avoiding all non-essential travel). Currently, China, Iran, South Korea and Italy are on the list. A link to the CDC risk assessment by country can be found here.
4. If possible, offer student housing for those who would otherwise travel to high risk areas over the break. Consider whether and how you should monitor personal travel by students and employees.
5. For individuals choosing to travel outside the U.S. during spring break, entry into the U.S. might involve additional scrutiny. It may be helpful for travelers to document details of their travel (e.g. trip itinerary, hotel or other travel receipts, or other evidence showing where they were during their time abroad), especially if there are questions relating to whether there was a visit to an area that has a COVID-19 outbreak. Students should be told whom to call if they are unable to return to the U.S.
6. Make sure you have thought about as many emerging issues as can be anticipated such as:
   a.    a possible COVID-19 diagnosis of a member of your institution’s community, 
   b.    tuition, financial aid, graduation and other issues if classes must be cancelled,
   c.    contract and other legal issues for program or conference cancellations.
7. COMMUNICATE, COMMUNICATE, COMMUNICATE. This bears repeating. And in that communication, do not forget about responding to fears, rumors and concerns.

Finally, though it is not spring break focused, we wanted to alert you to the Department of Education’s issuance of a guidance on compliance with Title IV of the Higher Education Act policies for students whose activities are impacted by COVID-19. A copy of the guidance can be found by clicking here.

Please contact Gail M. Norris, any other attorney in the Higher Education Practice Group, or your primary contact at Bond if you have questions about this topic.

For more information on issues facing colleges and universities, we invite you to subscribe to Bond’s Higher Education Law Report.