On July 9, 2021, the CDC released new guidance for schools for the upcoming 2021-2022 school year, which has been adopted by the IDPH (hereafter “Guidance”). A copy of the Guidance can be found here.  While Illinois has adopted the Guidance, we still expect additional guidance and clarifications from ISBE and IDPH over the next few weeks.

Under the Guidance, masks are only required to be worn on school transportation. In all other situations, the Guidance only makes recommendations as to masking and leaves the ultimate decisions to local school districts. We recommend that policy decisions surrounding masking and other prevention strategies be made in consultation with your local health department. Additionally, you can reach out to your school attorney and insurance carriers to discuss any legal or liability risks questions or concerns that you may have associated with various policy decision options.

There are several key takeaways from the Guidance, which are discussed below, which provide the following guidance for schools:

• Masks should be worn indoors by all individuals (age 2 and older) who are not fully vaccinated.
• Fully vaccinated students and staff do not have to wear masks.
• In general, masks do not need to be worn outdoors 
• All students and staff, regardless of vaccination status, must wear masks on school transportation.
• CDC recommends schools maintain at least 3 feet of physical distance between students within classrooms, but that physical distancing should not restrict or prevent a return to in person learning. When it is not possible to maintain a physical distance of at least 3 feet, such as when schools cannot fully re-open while maintaining these distances, it is especially important to layer multiple other prevention strategies, such as indoor masking.
• Localities should monitor community transmission, vaccination coverage, screening testing, and occurrence of outbreaks to guide decisions on the level of layered prevention strategies (e.g., physical distancing, screening testing).
• If schools districts are considering removing a prevention strategy, such as masking,  they should remove them one at a time and monitor closely (with adequate testing through the school and/or community) for any increases in COVID-19 cases and work with their local department of health

Below is a breakdown of the key points from the seven prevention strategies identified in the CDC Guidance.

 Vaccination

•  Strongly encouraged by CDC, but there are no federal or Illinois requirements that students or school personnel be vaccinated.
• The CDC guidance implies that schools can adopt a policy to ask for COVID-19 vaccination records from students, similar to other immunization records, and should follow the same privacy procedures for COVID-19 immunization as all other immunization records. While schools cannot condition attendance on vaccination, it could establish a policy that students or staff must be masked, unless proof of vaccination is shown.

Masks

• Masks are no longer required or recommended for fully vaccinated students and staff, but are still recommended for anyone who is not fully vaccinated.
• Masks do not need to be worn outdoors by anyone; however, in areas of substantial to high transmission, unvaccinated people should wear masks in crowded outdoor settings.
• Masks are required for all students and staff on school buses, regardless of vaccination status.
• Local school districts have the discretion and control to make mask use universally required, regardless of vaccination status. The Guidance provides reasons why a district may still require universal masking including having a student population who is not yet eligible for vaccination, lack of system to track or monitor vaccination status of school an staff or increasing COVID transmission in the school or community. 

Social Distancing

• Schools should maintain at least 3 feet of physical distance between all students within classrooms, combined with indoor mask wearing by people who are not fully vaccinated.
• If 3 foot distance cannot be maintained, it is important to ensure multiple other possible prevention strategies, such as indoor masking, ventilation, screening testing, handwashing, respiratory best practices, remaining home if sick (and getting tested), contact tracing (with quarantine and isolation) and/or proper cleaning and disinfection. 
• Six feet of distance is recommended between unvaccinated adults and between adults and students.
• Inability to maintain recommended social distancing is not a reason to deny or restrict in-person learning.

Cleaning and Disinfection

• Cleaning once a day is usually sufficient.  
• Disinfecting, when needed, removes any remaining germs on surfaces, which further reduces any risk of spreading infection.

Ventilation

• Improving ventilation is an important COVID-19 prevention strategy that can reduce the number of virus particles in the air.
• Can open multiple doors and windows, using child-safe fans to increase the effectiveness of open windows, and making changes to the HVAC or air filtration systems.
• Can open or crack windows in buses and other forms of transportation. Keeping windows open a few inches improves air circulation.

Handwashing and Respiratory Etiquette

• Handwashing and respiratory etiquette(covering coughs and sneezes) to keep from getting and spreading infectious illnesses including COVID-19.
• Teach and reinforce handwashing with soap and water for at least 20 seconds and remind everyone in the facility to wash hands frequently. 
• Can use hand sanitizer containing at least 60% alcohol (for teachers, staff, and older students who can safely use hand sanitizer).

 Quarantining & COVID Testing

• No quarantine or testing required for fully vaccinated students and staff after close contact with someone with COVID-19 in the absence of symptoms.
• Quarantining required for anyone not fully vaccinated, when exposed.  
• Students exposed in a classroom do not have to quarantine provided: (1) they and the person with COVID-19 were all wearing masks and (2)  there were other mitigation strategies in place, such as ventilation, social distancing, screening testing, handwashing, respiratory best practices, remaining home if sick (and getting tested), contact tracing (with quarantine and isolation) and/or  proper cleaning and disinfection.
• Students, teachers, and staff should stay home when they have signs of any infectious illness and be referred for testing and care.
• Continue to collaborate with state and local health departments to confidentially provide information about people diagnosed with or exposed to COVID-19.
• Identify which students, teachers, and staff with positive COVID-19 test results should isolate, and which close contacts should quarantine.
• Report new diagnoses of COVID-19 to their state or local health department as soon as they are informed.
• Notify, to the extent allowable by applicable privacy laws, teachers, staff, and families of students who were close contacts as soon as possible (within the same day if possible) after they are notified that someone in the school has tested positive.

Staying Home When Sick and Getting Tested

• Students, teachers, and staff who have symptoms of infectious illness, such as influenza(flu) or COVID-19, should stay home and be referred to their healthcare provider for testing and care.
• Employers should ensure that workers are aware of and understand these policies. 
• If a school does not have a routine screening testing program, the ability to do rapid testing on site could facilitate COVID-19 diagnosis and inform the need for quarantine of close contacts and isolation.
• Schools that do not have a universal mask requirement could require masking by students, teachers, and staff if they are experiencing onset of upper respiratory infection symptoms at school while waiting to be picked up or leave the school.

Screening Testing

• Screening testing identifies infected people, including those with or without symptoms (or before development of symptoms) who may be contagious, so that measures can be taken to prevent further transmission (fully vaccinated do not need to participate in screening testing and do not need to quarantine if they do not have any symptoms).
• Screening testing can be used to help evaluate and adjust prevention strategies and provide added protection for schools that are not able to provide optimal physical distance between students.
• Screening testing should be offered to students who have not been fully vaccinated when community transmission is at moderate, substantial, or high levels.
• At any level of community transmission, screening testing should be offered to all teachers and staff who have not been fully vaccinated. To be effective, the screening program should test at least once per week, and rapidly (within 24 hours) report results.
• To facilitate safe participation in sports, extracurricular activities, and other activities with elevated risk (such as activities that involve singing, shouting, band, and exercise that could lead to increased exhalation), schools may consider implementing screening testing for participants who are not fully vaccinated.
• Schools can implement screening testing of participants who are not fully vaccinated up to 24 hours before sporting, competition, or extracurricular events. Schools can use different screening testing strategies for lower-risk sports.

 Layered Prevention Strategies

Together with local public health officials, school administrators should consider multiple factors when they make decisions about implementing layered prevention strategies against COVID-19. Since schools typically serve their surrounding communities, decisions should be based on the school population, families and students served, as well as their communities. The primary factors to consider include:

• Though COVID-19 outbreaks have occurred in school settings, multiple studies have shown that transmission rates within school settings, when multiple prevention strategies are in place, are typically lower than – or similar to – community transmission levels.
• CDC continues to recommend masking and physical distancing as key prevention strategies.
• If school administrators decide to remove any of the prevention strategies for their school based on local conditions, they should remove them one at a time and monitor closely (with adequate testing through the school and/or community) for any increases in COVID-19 cases.
• Level of community transmission of COVID-19.
• COVID-19 vaccination coverage in the community and among students, teachers, and staff.
• Use of a frequent SARS-CoV-2 screening testing program for students, teachers, and staff who are not fully vaccinated. Testing provides an important layer of prevention, particularly in areas with substantial to high community transmission levels.
• COVID-19 outbreaks or increasing trends in the school or surrounding community.

CDC recommends that schools work with the local department of public health to assess the prevention strategies appropriate for their area by monitoring levels of community transmission (i.e., low, moderate, substantial, or high) and local vaccine coverage, and use of screening testing to detect cases in K-12 schools.

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