The Ontario Ministry of Education has issued important “operational guidance” that provides further detail regarding managing COVID-19 cases in schools.
Operational guidance: COVID-19 management in schools (the Guide) is a supplement to the more general guidance issued by the Ministry in July. It sets out uniform advice for elementary and secondary schools and includes a playbook for dealing with anticipated events.
Although the Guide includes some welcome direction, boards should beware that parts of it are inconsistent with the province’s current self-isolation model. The Guide is, therefore, not a substitute for boards’ own careful forethought and planning.
Below, we set out what the Guide says about reporting, health unit engagement, responding to an illness in the school and returning to school.
The Guide speaks to a new daily reporting requirement and the existing duty to report suspected cases.
Schools are to make daily reports of cases “associated with the school” and absenteeism though a reporting tool. These reports will go to both the Ministry and local public health unit for analysis and, when appropriate, follow-up.
Principals have a duty to report suspected COVID-19 cases in students to the local public health unit – i.e., a duty to report upon forming a belief that a student may have contracted COVID-19. The Guide calls attention to this duty, though also warns principals not to simply report “all instances of ill individuals.”
In advance of an outbreak, the Guide encourages principals to consult with their public health units about attendance concerns, managing individuals with symptoms and other matters.
Health unit engagement
Health units are to engage with schools and school boards based on daily and suspected case reports, with engagement triggered by the existence of an outbreak. The Guide defines an outbreak as:
"..two or more lab-confirmed COVID-19 cases in students and/or staff in a school with an epidemiological link, within a 14-day period, where at least one case could have reasonably acquired their infection in the school (including transportation and before or after school care)."
Health units are empowered to make orders to address outbreaks, though the Guide speaks to a more collaborative approach. It says, “the public health unit will assist in determining which cohort(s) may be sent home or if a partial or full school closure is required based on the scope of the outbreak.”
The school role in the event of an outbreak is straightforward. It is to provide public health with information (including class and cohort lists), communicate with community members based on public health direction and otherwise follow public health direction.
Response to illness in schools
The Guide says that schools should ask individuals who become ill during school hours to wait in an isolated room or area while awaiting pickup. School personnel in contact with such individuals should keep as much physical distance as possible and wear a surgical mask and eye protection. Afterwards, schools should sanitize as soon as reasonably possible.
The Guide’s direction on the next step is both vague and problematic. According to the Guide, schools are to “inform necessary stakeholders within the school community while maintaining confidentiality of the ill individual” but need not take any steps to send potential close contacts home. It says:
"Those who are identified as potential close contacts should remain cohorted. The local PHU will provide any further direction on testing and isolation of these contacts, if necessary. In most instances, testing and isolation would only be recommended for contacts of a confirmed COVID-19 diagnosis."
This guidance is difficult to reconcile with the Ontario self-isolation model, which would invite boards to immediately send home close contacts of symptomatic individuals rather than wait up to several days for a diagnosis or test result. Moreover, the Guide includes no direction about how to deal with students, teachers and visitors who have been in a school and, soon after, become symptomatic.
School boards should decide now whether to follow this particular part of the Guide or engage in a more protective approach aligned with the Ontario model. This protective approach also calls for a response to absences by teachers and students who become symptomatic (and not simply illness that arise in schools).
Boards may wish to ask teachers and students to report such absences so they can assess the probability of in-school exposure and the need to communicate with students and parents about in-school exposure even before the case is “confirmed.” As the Guide suggests, schools will ordinarily be able to engage in such communications without revealing the identity of symptomatic individuals.
Return to school
The Guide gives the following direction regarding return to school:
- Individuals who had a COVID-19 test because they were showing symptoms but tested negative should not return to school until at least 24 hours after their symptoms have resolved.
- Where a student or staff member tests positive for COVID-19, the local public health unit will be in contact with the school to provide further direction on returning to school.
The Guide discourages boards from requiring medical notes and test results as a condition of return, identifying such conditions as “barriers to return to school.”
While health units will no doubt be on alert to the risk of COVID-19 spread in schools this fall, they do govern themselves independently of the Ministry and the province. The Ministry’s new Guide, however, may encourage the kind of support and collaboration with public health units that school boards need.
The Guide, however, fails to give good direction on how boards should respond to individuals who become symptomatic while in school or who were recently in school. The current provincial guidance on self-isolation encourages a quick reaction to potential outbreaks by requiring those who have been in close physical contact with symptomatic individuals to self-isolate promptly.
In light of the provincial model, school boards should be cautious in following the Guide, which invites waiting a “confirmed case” and public health intervention before taking steps to keep close physical contacts of the potential COVID-19 infected individual out of schools.
Please get in touch with any of the contacts below if you have questions about COVID-19 and the return to school.