Communicable Disease - Pandemic Continuity of Operations Plan

This Continuity of Operations Plan has been developed to meet the requirements of the amended New York State Labor Law Section 27-c and New York State Education Law paragraph m of subdivision 2 of Section 2801-a which requires public employers to prepare a plan for the continuation of operations in the event that the Governor declares a public health emergency involving a communicable disease. This plan is built upon the components of the District-Wide School Safety and the Building-Level Emergency Response Plan(s). The Plan includes elements of the COVID-19 Reopening Plan and will be updated regularly to reflect current guidance and best practices. The District-Wide School Safety Team assumes responsibility for development and compliance with all provisions of this plan and implementation at the building level through the Building-Level Emergency Response Team.

The district will work closely with the Washington County Department of Health (local health department) to determine the need for activation of this plan. The district will report suspected and confirmed cases of communicable diseases (e.g., influenza, coronavirus, etc.) on the monthly Communicable Disease Report, (DMS-485.7/93; HE-112.4/) and submit it to the local health department. Depending on the severity of the disease, the district may be required to report information more frequently and in another format (i.e., daily for COVID-19).

The local health department will monitor countywide communicable disease cases and inform school districts as to appropriate actions.

When this plan is activated, the District-Wide School Safety Team may invite additional people to the meetings to aid in the planning efforts:

District Medical Director
School nurse(s)
Technology Director
Human Resources Director
Business Official
Facility Director
Food Service Director
Transportation Coordinator
Public Information Officer
Curriculum Director

In developing this plan, the District gathered input from the Hudson Falls Administrators, Teachers Association, School-Related Personnel, Aides & Assistants bargaining units.

No content of this plan is intended to impede, infringe, diminish, or impair the rights of us or our valued employees under any law, rule, regulation, or collectively negotiated agreement, or the rights and benefits which accrue to employees through collective bargaining agreements, or otherwise diminish the integrity of the existing collective bargaining relationship.

The District reserves the right to modify the plan as necessary, with notification to the respective collective bargaining units.

Planning Assumptions

This plan was developed based on information, best practices, and guidance available as of the date of publication. The following assumptions have been made in the development of this plan:

The health and safety of our employees and contractors, and their families, is of the utmost importance.
The circumstances of a public health emergency may directly impact our own operations.
Impacts of a public health emergency will take time for us to respond to, with appropriate safety measures put into place and adjustments made to operations to maximize safety.
The public and our constituency expect us to maintain a level of mission-essential operations.
Resource support from other jurisdictions may be limited based upon the level of impact the public health emergency has upon them.
Supply chains, particularly those for personal protective equipment (PPE) and cleaning supplies, may be heavily impacted, resulting in considerable delays in procurement.
The operations of other entities, including the private sector (vendors, contractors, etc.), non-profit organizations, and other governmental agencies and services may also be impacted due to the public health emergency, causing delays or other disruptions in their services.
Emergency measures and operational changes may need to be adjusted based upon the specific circumstances and impacts of the public health emergency, as well as guidance and direction from public health officials and the governor.

Concept of Operations

The Superintendent, their designee, or their successor holds the authority to execute and direct the implementation of this plan. Implementation, monitoring of operations, and adjustments to plan implementation may be supported by additional personnel, at the discretion of the Superintendent.

Communication with parents, students, staff, and the school community is important throughout a pandemic outbreak. Communication methods will include postings to the district website, general mailings, email, social media, school communication apps, and public media. The district Public Information Specialist (Communications) has been designated to coordinate this effort. Communications will work closely with the Director of Technology (Tech) to ensure the proper function of all communication systems

The Superintendent, their designee, or their successor will maintain awareness of information, direction, and guidance from public health officials and the Governor’s office, directing the implementation of changes as necessary.

Upon resolution of the public health emergency, the Superintendent, their designee, or their successor will direct the resumption of normal operations or operations with modifications as necessary.

Mission Essential Functions

When confronting events that disrupt normal operations the District is committed to ensuring that essential functions will be continued even under the most challenging circumstances.

Essential functions are those functions that enable an organization to:

Maintain the safety of employees, contractors, and our constituency.
Provide vital services.
Provide services required by law.
Sustain quality operations.
Uphold the core values of the District

A. Essential Functions/Positions/Titles During a Governor Mandated and/or Public Health Mandated Campus Shutdown

The District has developed this plan to prepare for any future government ordered shutdowns that may occur, similar to the coronavirus shutdown in the spring of 2020. Attachment 1 includes a list of essential positions that would be required to be on-site or in district to continue to function as opposed to those positions that could work remotely. The list includes:

Title – a list of positions/titles considered essential (i.e., could not work remotely) in the event of a state-ordered reduction of in-person workforce.
Description – brief description of job function.
Justification – brief description of critical responsibilities that could not be provided remotely.
Work Shift – brief description of how work shifts of essential employees and/or contractors will be staggered in order to reduce overcrowding in the district.
Protocol – how precise hours and work locations, including off-site visits, will be documented for essential employees and contractors.

Continuity of operations could be severely impacted by a loss of staff. The table below describes the procedures for maintaining essential functions and services by planning for backup personnel.

Role/Topic: Overall operations

Task: Have decision-making authority for the district; make district policies and procedures to reflect crisis response

Backups: Those listed are assigned to this role: Superintendent; Executive Director for Business and HR; Director of Facilities

Role/Topic: Business Office

Task: Maintain overall function and facilities; review essential functions and responsibilities of backup personnel; monitor utilization of supplies, equipment, contracts, and provided services and adjust as necessary

Backups: Financial Support Specialist; Payroll; Overall Operations: Treasurer

Role/Topic: Facilities

Task: Keep the Business Office informed of staffing issues and of the point at which buildings can no longer be maintained; provided building administrators with procedures for maintaining essential building functions (e.g., HVAC system operation, alarms, security, etc.) along with a lost of telephone numbers of outside companies and alternates for repair and maintenance of these systems; meet with staff and monitor their ability to maintain essential function

Backups: Superintendent of Buildings and Grounds

Role/Topic: Human Resources

Task: Monitors absenteeism and ensures appropriate delegation of authority; work with bargaining units to develop the plan for emergency use of personnel in non-traditional functions and changes in the normal work-day such as alternate or reduced work hours; working from home, etc.

Backups: Recruitment/Staffing: Exec. Dir Business & HR Workplace Safety; Exec. Dir Business & HR Training; Exec. Dir Business & HR Labor Law Compliance; Exec. Dir Business & HR Compensation Planning; Executive Dir. Business & HR

Role/topic: Continuity of instruction

Tasks: Will be implemented in the event of significant absences or school closure. Alternate learning strategies will include: Hard copy, self-directed lessons; use of mobile media storage devices for lessons (CDs, Jump Drives, iPads); on-line instruction; online resources; online textbooks); communication modalities for assignment postings and follow-up: telephone; Postal Service; cell phone; cell phone mail; text messages; email; automated notification systems; website postings

B. Working/Learning Remotely

The District will assess devices and technology needs of all non-essential employees and contractors in order to enable telecommunity. Options for assessing District needs include stakeholder meetings or surveys to ascertain:

Who will need devices and/or peripherals at home,
What programs will need to be added to these devices, and
The availability of viable existing at-home internet service.

The information from these surveys will be used to determine what items need to be purchased, which programs need to be installed on devices and if appropriate Internet bandwidth can be provided to those in need.

C. Staggered Shifts

Depending on the exact nature of the communicable disease and its impact, the District is prepared to use the strategies below to reduce traffic congestion and maintain social distancing:

Limiting building occupancy to 25%, 50% or 75% of capacity or the maximum allowable by state or local guidance
Forming employee work shift cohorts to limit potential contacts.
Limit employee travel within the building and/or between buildings.
Limit restroom usage to specific work areas.
Stagger arrival and dismissal times.
Alternate work-days or work weeks
Implement a four-day work week.
Limit or eliminate visitors to the building

The District may need to include additional strategies based on updated federal, state, and local guidance.

D. Personal Protective Equipment (PPE) and Face Coverings

The District will procure a six-month supply of face coverings and PPE required for essential work tasks. Disposable PPE will be provided in quantities of at least two pieces per work day. The Business Office will contact vendors to obtain the PPE.

PPE Type: N-95

Task/Role: Nurses; cleaners/custodians (based on the disinfectants used)

PPE Type: Face shields

Task/Role: Nurses; special education

PPE Type: Gowns

Task/Role: Nurses; special education

PPE Type: Gloves

Task/Role: Nurses; special education; cleaners/custodians; maintenance/mechanics

PPE Type: Cloth face coverings*

Task/Role: All faculty, staff and students

*Cloth face coverings are not considered personal protective equipment by OSHA because their capability to protect the wearer is unknown. However, cloth face coverings are important as a source control for COVID-19 and provides some protection to the wearer. As such, OSHA strongly encourages workers to wear face coverings.

Those individuals that are required to wear N-95 respirators will be fit-tested and medically screened prior to use to ensure they are physically able to do so.

The use of cloth face coverings to reduce the spread of communicable diseases is important to the health and safety of faculty, staff and students. Cloth face coverings are meant to protect other people in case the wearer is unknowingly infected (asymptomatic) and are essential when physical distancing is difficult. Information will be provided to faculty, staff and students on proper use, removal, and cleaning of cloth face coverings. All faculty, staff and students will be encouraged to utilize their own personal face coverings but the District will secure and provide face coverings as needed.

PPE and face coverings will be stored in a manner which will prevent degradation. These supplies will be monitored to ensure integrity and track usage rates. District communication on how to access PPE will be provided.

E. Response Protocols for Preventing Spread

The District-Wide School Safety Team will meet to determine the need for activation of a pandemic response based on internal monitoring and correspondence with the local health department and other experts. This plan will not be activated unless there is a governor or state/local health department mandated communicable disease emergency order.

The Incident Command Structure at both the District and Building level will be informed that the response effort has been enacted. These individuals will meet to discuss the plan’s activation and review responsibilities and communication procedures.
Communications will work closely with the IT department to re-test all communication systems to ensure proper function. The District-wide School Safety Team and Building-Level Emergency Response Teams will assist in this effort.
An alert will be sent to the school community upon activation of this plan. The communication will be based on the latest information from federal, state and local health authorities.
If the decision is made to close a school building, the District will notify the NYS Education Department and District Superintendent.

The district will assign a Communicable Disease Safety Coordinator, Head Nurse, whose responsibilities include continuous compliance with all aspects of the District’s reopening plan and any phased-in reopening activities necessary to allow for operational issues to be resolved before activities return to normal or “new normal” levels. The coordinator shall be the main contact upon the identification of positive communicable disease cases and are responsible for subsequent communication. Coordinators shall be responsible for answering questions from students, faculty, staff, and parents or legal guardians of students regarding the public health emergency and plans implemented by the school.

Hand Hygiene

Faculty, staff, and students will be trained on proper hand hygiene. Information will be provided to parents and/or legal guardians on ways to reinforce hand hygiene at home. The District will provide stations around the school buildings:

For hand washing: soap, running water, and disposable paper towels.
For hand sanitizing: an alcohol-based hand sanitizer containing at least 60% alcohol for areas where handwashing facilities may not be available or practical. Accommodations for students who cannot use hand sanitizer will be made.

Communicable Disease Exposures

The District must be prepared for communicable disease outbreaks in their local communities and for individual exposure events to occur in their facilities, regardless of the level of community transmission. The Centers for Disease Control and Prevention (CDC) and New York State Department of Health (NYSDOH) have provided the following current recommendations for strategies to follow after an exposure:

Close off areas used by a sick person and not using these areas until after cleaning and disinfection has occurred;
Open outside doors and windows to increase air circulation in the area.
Wait at least 24 hours before cleaning and disinfection. If waiting 24 hours is not feasible, wait as long as possible;
Clean and disinfect all areas used by the person suspected or confirmed to have a communicable disease, such as offices, classrooms, bathrooms, lockers, and common areas.
Once the area has been appropriately cleaned and disinfected it can be reopened for use. Individuals without close or proximate contact with the person suspected or confirmed to have a communicable disease can return to the area and resume school activities immediately after cleaning and disinfection.
If more than seven days have passed since the person who is suspected or confirmed to have a communicable disease visited or used the facility, additional cleaning or disinfection is not necessary, but routine cleaning and disinfection should continue.
The District will follow this guidance, along with any additional guidance issued by the CDC and NYSDOH in the future relative to the pandemic then in existence.

Returning after Illness

The District has established protocols and procedures, in consultation with the local health department(s), about the requirements for determining when individuals, particularly students, who screened positive for communicable disease symptoms can return to the in-person learning environment at school. This protocol includes:

Documentation from a health care provider following evaluation Negative diagnostic test result
Symptom resolution, or if positive for a communicable disease, release from isolation

The District will refer to the NYSDOH’S “Pre-K to Gr 12 COVID-19 Toolkit” and other applicable guidance regarding protocols and policies for faculty, staff, and students seeking to return to work after a suspected or confirmed communicable disease case or after the faculty or staff member had close or proximate contact with a person with a communicable disease.

The District requires that individuals who were exposed to a communicable disease complete quarantine and have no symptoms before returning to in-person learning. The discharge of an individual from quarantine and return to school will be conducted in coordination with the local health department.

Cleaning/Disinfecting

The District will ensure adherence to hygiene and cleaning and disinfection requirements as advised by the CDC and NYSDOH, including “Guidance for Cleaning and Disinfection – Public Spaces, Workplaces, Businesses, Schools and Homes” and other guidance, as applicable.

Attachment 2 describes cleaning and disinfection protocols and procedures for the District. Regular cleaning and disinfection of the facilities will occur, including more frequent cleaning and disinfection for high-risk and frequently touched surfaces. This will include desks and cafeteria tables, which will be cleaned and disinfected between each individual’s use. Cleaning and disinfection will be rigorous and ongoing and will occur at least daily, or more frequently as needed.

The District will ensure regular cleaning and disinfection of restrooms. Restrooms will be cleaned and disinfected more often depending on frequency of use.

Employee Leave

We would recommend the following language in lieu of the above, as we do not know what the leave requirements or leave necessity will be in the future:

Unless required by Federal, State or local law, the District will follow the leave provisions of the respective collective bargaining agreements and/or the leave provisions contained in the employee handbooks for non-bargaining unit employees.

F. Contact Tracing Supports

The District will notify the state and local health department immediately upon being informed of any positive communicable disease diagnostic test result by an individual within school facilities or on school grounds, including students, faculty, staff, and visitors of the District.

The District will assist with contact tracing by:

Keeping accurate attendance records of students and staff members
Ensuring student schedules are up to date Keeping a log of any visitor which includes date and time, and where in the school they visited
Assisting the local health department in tracing all contacts of the individual in accordance with the protocol, training, and tools provided through the NYS Contact Tracing Program

The District, in consultation with the local health department, will determine what process will be followed when communicable disease cases are discovered in the school (e.g., how many individuals will be quarantined, closing of areas or classrooms, etc.).

Confidentiality must be maintained as required by Federal and State laws and regulations. School staff should not try to determine who is to be excluded from school based on contact without guidance and direction from the local health department.

G. Housing for Essential Employees

Emergency housing for essential workers is not considered to be required for school faculty and staff. If a need for emergency housing arises, the District will coordinate with the Washington County Health Department to help identify and arrange for the housing needs.

Recovery

Re-establishing the normal school curriculum is essential to the recovery process and should occur as soon as possible. The District will

Work toward a smooth transition from the existing learning methods to the normal process.
Use the described communication methods to keep the school community aware of the transition process.
Work closely with the New York State Education Department to revise or amend the school calendar as deemed appropriate.
Evaluate all building operations for normal function and re-implement appropriate maintenance and cleaning procedures.

Each Building-Level Post-incident Response Team will assess the emotional impact of the crisis on students and staff and make recommendations for appropriate intervention. The District-Wide School Safety Team and Building-Level Emergency Response Teams will meet to de-brief and determine lessons learned with input from all essential functions. The District-Wide School Safety Plan and Building-Level Emergency Response Plans will be updated accordingly.

Curriculum activities that may address the crisis will be developed and implemented.

Attachment 1:

Title: Superintendent

Description: Superintendent of Schools, Secretary

Justification: Districtwide decision making

Work shift: 8 a.m. to 5 p.m.