Outbreaks, Communication and Reporting
What is the definition of an outbreak in pre-K-12 schools?
CDC recommends that all states define school-associated outbreaks according to the standards established by the Council of State and Territorial Epidemiologists (CSTE):
multiple cases comprising at least 10% of students, teachers, or staff within a specified core group” (e.g., extracurricular activity, cohort group, classroom, before/after school care, etc.) or
at least three cases within a specified core group meeting criteria for a probable or confirmed school-associated COVID-19 case (laboratory-positive by PCR or antigen testing) with symptom onset or positive test within 14 calendar days of each other; who were not identified as close contacts of each other in another setting outside of the school setting (i.e., household); and that are epidemiologically linked in the school setting or a school-sanctioned activity
As recommended by the CDC, IDPH is adopting the CSTE definition of school-associated outbreaks for K-12 settings and applying the standard to all school-based pre-K-12 settings. Schools should consult with their local health department (LHD) to determine if their circumstances and cases constitute a school-associated outbreak, using either of the definitions above as determined by the LHD. This would prompt an investigation by the LHD that may result in recommendations for testing and quarantining of students/staff in the affected classroom(s).
Outbreak testing is strongly recommended for schools in outbreak status. Implementation of outbreak testing should begin as soon as possible from the date the outbreak is declared and at least within three days. Schools should conduct twice weekly testing of all staff (regardless of vaccination status) and students in impacted classroom(s), grade(s), and extracurricular activities, or, depending on the circumstances, the entire student body, unless the LHD recommends otherwise. If a student is linked to an outbreak setting, but not a close contact, those students must be tested twice per week until the outbreak is over to continue participating in extracurricular activities, including sports. Testing should continue until the school has gone two incubation periods, or 28 days, without identifying any new cases. If testing is not already in place for screening, schools should make plans to deploy outbreak testing when needed. A listing of free testing sites is available at https://dph.illinois.gov/testing. Additionally, SHIELD Illinois can be quickly deployed to a school setting by emailing Beth Heller, senior director of External Affairs for SHIELD, at email@example.com. Schools can also utilize BinaxNOW rapid antigen testing for outbreak response by emailing firstname.lastname@example.org.
If there is a large outbreak of COVID-19 within a school, what are the recommendations for temporary school closure?
Pursuant to the superintendent’s declaration under Section 10-30 of the Illinois School Code, a school or school district may only enter into an adaptive pause in consultation with the local health department (LHD) and consistent with guidance or requirements from such LHD. In general, an adaptive pause may not be necessary if the school follows all appropriate mitigation strategies. When the large number of new cases makes it difficult for schools and LHDs to conduct prompt investigations to identify and to exclude/quarantine close contacts, or if there is an unsafe environment due to lack of masking and/or testing, adaptive pauses can be useful to ensure individuals who are potentially infectious are excluded from school. Adaptive pauses using remote learning may not be employed due to staffing shortages in schools. Schools taking adaptive pause should pause from all activities, including extracurricular activities.
Are there alternative strategies to school closure during a large outbreak that may be considered or employed?
School closure should be the absolute last resort to managing an outbreak due to the critical role of in-person learning to students’ overall wellbeing. In general, an adaptive pause should not be necessary if the school is following all appropriate mitigation strategies. If the school is following guidance regarding masking, testing, identifying and excluding COVID-19 cases and their close contacts, cleaning and optimizing ventilation then an adaptive pause should not be necessary to mitigate an outbreak, and students are best served by continuing to provide in-person instruction. In consultation with the local health department, a school may implement alternative strategies less drastic than closure. Options might include:
Transitioning the classroom or grade where the outbreak is occurring to remote learning, especially where physical distancing is challenging (e.g., early childhood)
Suspending affected classes or closing playgrounds
Canceling non-essential activities and meetings
Keeping students in constant class groups or classrooms and moving teachers routinely between classes
Increasing spacing between students in classes
Shortening the school week
Staggering school start and lunch/break times across year groups or classes
Communication and Reporting
Are schools required to report information to the local health department including cases, type and onset of symptoms, number of exposed persons, etc.?
Yes. Schools must report information needed for mitigating the spread of COVID-19 infection to the local health department for use in surveillance, contact tracing, and other public health activities. Schools must be aware of records and confidentiality laws pertaining to school student records, including exceptions to release of information in the event of an emergency, and requirements to notify parents and to create a record of emergency releases of information. (105 ILCS 10/6(a)(7); 23 Il. Admin. Code 375.60).
Is it a Family Educational Rights and Privacy Act (FERPA) violation to notify the LHD/IDPH or staff and parents of a confirmed or probable case(s) in our school?
No. A laboratory confirmed case of COVID-19 is reportable within three hours to the local health department per the Communicable Disease Code. Identifiable information on a student or staff member, including name and contact information, is reportable to IDPH or to the local public health authority for any notifiable disease or condition.
Schools must be aware of records and confidentiality laws pertaining to school student records, including exceptions to release of information in the event of an emergency, and requirements to notify parents and create a record of emergency releases of information. (105 ILCS 10/6(a)(7); 23 Il. Admin. Code 375.60).
Does contact tracing violate the Health Insurance Portability and Accountability Act (HIPAA)?
No. The HIPAA Privacy Rule allows for reporting by covered entities to public health agencies for the purpose of preventing the spread of infectious diseases. HIPAA recognizes the legitimate need for public health authorities, and others responsible for ensuring public health and safety, to have access to protected health information to carry out their public health mission.
If we have a case of COVID-19 in a student at our school, what is our responsibility for notifying schools attended by siblings of the case?
There is no need to notify a school attended by siblings of a sick individual. If the sick individual tests positive for COVID-19 or becomes a probable case, the local health department conducting contact tracing will place siblings in quarantine and facilitate parental notification to the school(s) attended by siblings of the case.
Besides public health authorities, who should be notified of a case of COVID-19 at our school? Must we notify the entire district, or only the classroom or the building?
Communication of a confirmed or probable case of COVID-19 to the district and to the school community should align with the school’s policy for notification of cases of communicable diseases. The communication message should counter potential stigma and discrimination. It is critical to maintain confidentiality of the student or staff member as required by the Americans with Disabilities Act, the Family Education Rights and Privacy Act, and the Illinois School Student Records Act.