COVID-19 Monitoring and Response Plan

VI. Alert Levels and Response

According to the level of incidences of COVID-19 cases on campus, the university will adapt its operations as necessary using four Alert Levels. The thresholds or triggers for each level are explained below.

Level Zero: No health alert - following normal operations

• Vaccine or effective therapeutic treatment is widely available.
• No cases on campus, very few to no cases in Frederick County.

Level One: Low Level Health Alert (see Appendix for threshold data)

• Fewer than 36 confirmed and active student cases of the coronavirus (2% of FT+PT UG population).
• Fewer than 28 confirmed and active residential student cases (2% of Residential population).
• Fewer than 10 confirmed and active Frederick student cases (2% of GCPS population FT+PT).
• Fewer than three confirmed and active Seminarian cases of the coronavirus (2% of population).
• Fewer than 2% of employees with confirmed cases.
• Positive Test % (Positivity) in random surveillance testing less than 4%.
• Fewer than 10% of confirmed cases hospitalized.
• Campus isolation spaces at 50% or less capacity (27 out of 55 beds).

Potential Responses at Level One

The university will likely assume a Level One Health Alert for the first two weeks of the Fall 2020 semester until monitoring results can inform the Emergency Action Team. The university will continue to follow the health and safety protocols published in the Mount Safe COVID-19 Response Team Report for Fall 2020 which includes isolation of COVID-19 cases and performing contact tracing. Wearing of masks and physical distancing are the main risk reduction measures that all employees, students and seminarians should be following.

Level Two: Heightened Level Health Alert (see Appendix for threshold data)

• 37 to 55 confirmed and active UG student cases of the coronavirus (2% to 3% of students).
• 29 to 42 confirmed and active residential UG student cases of the coronavirus.
• Three to five confirmed and active seminarian cases of the coronavirus.
• 2% to 4% of employees with confirmed cases.
• Positive Test % (Positivity) in random surveillance testing between 4-8%.
• 11% to 15% of confirmed cases hospitalized.
• Campus isolation spaces at 51% to 98% capacity (28 to 54 out of 55).
• Three to four weeks in a row of growth in cases (from community transmission).

Potential Responses at Level Two

The university may consider these additional risk reduction measures among other alternatives:

• Reduce or restrict the size of certain on-campus gatherings (e.g., lectures).
• Reduce or place further restrictions on athletic team practices and travel.
• Consider expanding the number of isolation spaces.
• Increase surveillance testing and contact tracing efforts.
• Reduce or restrict student club and other extra-curricular activities.
• Further restrict student travel off campus.
• Require commuter students to attend all classes remotely and not come to campus.
• Reduce further the number of students physically in classes.
• Move more employees to telework.

Level Three: Advanced Level Health Alert

• Greater than 55 confirmed and active student cases of the coronavirus.
• Greater than 42 confirmed and active residential student cases of the coronavirus.
• Significant increase in the rate of new confirmed cases.
• Greater than five confirmed seminarian cases of the coronavirus.
• Greater than 4% of employees with confirmed cases.
• Positive Test % (Positivity) in random surveillance testing greater than 8%.
• Greater than 15% of confirmed cases hospitalized.
• Five weeks in a row of growth in cases (from community transmission).
• Campus isolation spaces at 98% capacity (54 out of 55).

Potential Responses at Level Three

At Level Three, the university may consider these additional risk reduction measures beyond Level Two among other alternatives:

• Move all class instruction to remote delivery.
• Increase teleworking of employees.
• Stop all athletic team activities.
• Send students home for the remainder of the semester.

VII. Communication

All decisions and actions of the Emergency Action Team will be communicated first to the President’s Cabinet and, if necessary, to the Executive Committee of the Board of Trustees.

The Director of Public Relations and Communications will develop and disseminate messages to the Mount Community regarding Emergency Action Team actions via the Mount Safe Initiative site. Any change in the Alert Level will be communicated President directly to the Mount community.

The Mount Alert system may be used in emergency situations to inform the Mount Community of urgent matters.

Announcements about the health status of specific individuals is restricted by FERPA¹.

• FERPA prohibits educational agencies (e.g., school districts) and institutions (i.e., schools) from disclosing personally identifiable information (PII) from students’ education record without the prior written consent of a parent or “eligible student,” unless an exception to FERPA’s general consent rule applies. For instance, pursuant to one such exception, the “health or safety emergency” exception. Under the FERPA health or safety emergency exception, an educational agency or institution is responsible for making a determination, on a case-by-case basis, whether to disclose PII from education records, and it may take into account the totality of the circumstances pertaining to the threat.
• FERPA permits educational agencies and institutions to disclose, without prior written consent, PII from student education records to appropriate parties in connection with an emergency, if knowledge of that information is necessary to protect the health or safety of a student or other individuals.
• Typically, law enforcement officials, public health officials, trained medical personnel, and parents (including parents of an eligible student) are the types of appropriate parties to whom PII from education records may be disclosed under this FERPA exception.
• An institution may disclose information about a student’s illness to other students and their parents in the school community without prior written parental or eligible student consent ONLY if a student’s identity is not personally identifiable, whether through single or multiple releases, and taking into account other reasonably available information. One could announce that “a student on campus has tested positive for COVID-19” but one probably should not announce to a class “a student in this class has tested positive” because students likely would be able to figure out who it is based on their absence.
• Student information generally should not be released to the media. Under FERPA it should only be released to authorized Mount employees and relevant government officials, such as public health officials.
• See the full Department of Education document for details.

¹STUDENT PRIVACY POLICY OFFICE FERPA & Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions (FAQs) March 2020.

VIII. Partnering with State and County Health Departments

The Emergency Action Team and other university officials will remain in communication with the Maryland Department of Health and the Frederick County Health Department and will closely monitor their published guidance and requirements.

IX. Appendix

• MD population = 6,046,000
• Frederick Co. population = 259,500
• The best estimate for frequency of cases in MD currently (7/7/20) would be 1% to 3%. Rationale: From the table above, the number of new confirmed cases in the last 14 days (active cases) in Maryland is 9 cases per 10,000 or 0.1%. According to the positivity rate the number of positive tests of all those tested is 4.5%. Confirmed cases underestimates the true number because not everyone goes for testing, especially asymptomatic cases. Positivity rate overestimates the true number because those that go for testing usually have a reason to do so (i.e., symptoms).
• The best estimate for the Level 3 threshold is between 1% and 5% confirmed active cases. A threshold number that would indicate an outbreak is imminent can be derived from the 8 May No. of Confirmed Cases (22 per 10,000 or 0.2%) which was the highest value in the table. Cases were declining steadily at that time. Also the 2 June positivity rate (9%) is during the period where asymptomatic testing was allowed which makes it a more representative statistic.