The COVID-19 Pandemic has left more questions than answers. Recently, the New York State Department of Health released updated guidance regarding COVID-19 policies and procedures. New York State is responsible for adhering to federal guidelines set forth by the federal government, including President Biden’s “Path out of the Pandemic” Action Plan. Part of this plan prioritizes keeping schools open safely. Schools are required to implement a plethora of safety measures to return to in-person learning which includes vaccination, appropriate use of face masks, physical distancing, COVID testing, and the use of ventilation and air filtration systems.
Guidance on quarantining have been updated to reflect the recent availability of COVID-19 vaccinations. Per the New York State Department of Health, all close contacts with someone with COVID-19 must quarantine unless they are fully vaccinated. A close contact is defined as anyone exposed to an individual with COVID-19 for a cumulative of 15 minutes over the course of a 24-hour period. Guidance is only valid if the individual does not present symptoms congruent with COVID-19. Furthermore, it is recommended that such vaccinated individuals who have been in close contact obtain a test 3 to 5 days after exposure and to wear a mask until a negative test is received.
Due to the value of in-person learning, schools are recommended to implement physical distancing when possible. The following are recommended distancing guidelines:
- A distance of at least 3 feet is recommended between all students and at least 6 feet is recommended between students and staff, and between staff who are not fully vaccinated.
- It is important to note that schools cannot exclude students from in-person learning to meet the distancing requirement.
Per Governor Hochul’s announcement, daily reporting to the New York State School COVID Report Card resumed on September 13th. All schools are required to submit a daily report between 7am and 5pm for each operational day of the school year.
Regarding sports and extracurriculars, schools are obligated to consider mitigation measures outlined in CDC guidance. Schools should consider screening testing of participants who are not fully vaccinated up to 24 hours before an event. High-risk sports and extracurricular activities should be virtual or canceled in areas of high community transmission unless all participants are fully vaccinated.
Screening testing refers to the testing of asymptomatic individuals even if there is no reason to suspect infection. Results of screening tests are reported to the people whose specimens have been tested and to their healthcare providers. Unvaccinated teachers and staff, as well as contractors, working in P-12 schools are required to undergo weekly COVID- 19 testing. P-12 schools are required to ensure teachers, staff, and applicable contractors have COVID-19 testing performed weekly. However, P-12 schools are required to offer COVID-19 screening testing to unvaccinated students on a weekly basis.
In addition, schools must have the capacity (either directly on-site or via referral) to provide COVID-19 diagnostic testing, for any students, teachers or staff, as well as contractors, regardless of his/her vaccination status and community level of transmission, who are either symptomatic or have been exposed to someone with COVID-19 within the last 14 days. Diagnostic testing differs from screening testing in that diagnostic testing denotes that the individual is exhibiting COVID-19 symptoms or has had exposure to someone with COIVD-19, while screening testing signals that the individual is not currently exhibiting COVID-19 symptoms.
Authorized tests under any testing category (i.e., screening, diagnostic, and/or pooled testing) are considered to be those that are FDA or DOH authorized and must be performed by a NYS-approved laboratory to ensure all NYS regulatory and reporting requirements are met.
For more information, please see the presentations and webinars done by the New York Department of Health in September 2021 and the Commissioner’s determination letter released in September 2021.
Written by Nicholle Mezier, CPA, MBA. If you would like to learn more about this topic, please contact:
Shari Diamond, CIA
Shari has been with Cerini & Associates, LLP since 2008 where she works primarily with the firm’s school district clients providing internal audit and claims audit services. She has over twenty years’ experience performing internal audits, risk assessments, and compliance reviews, as well as recommending processes to strengthen the internal controls environment while increasing efficiencies. Her prior experience at PWC and Northrop Grumman included performing Information Technology audits.