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Arizona Law "New Safe Return" Plan: 4.0 MITIGATION PLAN

Guidelines for the College of Law's new safe return to campus

4.0 MITIGATION PLAN

This section lays out a mitigation plan for fully reopening Arizona Law, which is our primary goal and not the same as “life before COVID-19.” This Plan consists of three principal layers:

  1. At-home mitigation, including social distancing, masking, personal hygiene measures, and more.
  2. On-campus mitigation, including:
    1. Free and voluntary baseline antibody blood testing provided by UArizona;
    2. Campus access restricted to Arizona Law faculty, staff, and students, with limited exceptions;
    3. Daily screening, temperature checks, plus follow-up medical care and testing provided by University health services and contact tracing provided by UArizona or designee;
    4. Schedule, classroom, and teaching modifications, incorporating social distancing;
    5. Masking and other personal protection measures;
    6. Physical plant monitoring and hygiene.
  3. Enhanced viral monitoring (Appendix A), including:
    1. Voluntary, biweekly testing of a subgroup of the Arizona Law community for COVID-19 and rhinovirus;
    2. Contact tracing provided by UArizona or designee for any individual who tests positive for COVID-19.

Enhanced viral monitoring is designed as a voluntary, supplemental measure of protection involving sampling of a campus cohort. This is a research study component under IRB review. If this component does not advance for whatever reason, the entirety of section 4.6 and some elements of section 4.8 will become inoperative, but no other aspect of the Plan shall change as a result.

The remainder of this section provides an overview of all three mitigation layers and a detailed Plan for at-home mitigation, baseline viral testing, daily screening and temperature checks, enhanced viral monitoring, and contact tracing. Other on-campus mitigation measures and their impact on Arizona Law operations receive more comprehensive treatment in subsequent sections. 

On-campus or off, the actions of every member of the Arizona Law community have the potential to affect the health of all other members. Arizona Law therefore strongly recommends that all faculty, staff, and students follow the latest public health guidelines when off-campus, including those pertaining to social distancing, face coverings, and personal hygiene.

To facilitate compliance, Arizona Law will keep all community members continuously updated on CDC, Arizona, and Pima County public health guidance at Arizona Law’s official COVID-19 Response website and through other channels. It shall be part of Arizona Law’s official Pledge for a Safe Return (Appendix B) that all community members keep themselves informed about the latest public health guidance and follow that guidance to the extent their personal circumstances permit.

The College of Law campus includes the Law Commons (main building and Daniel F. Cracchiolo Law Library), Rountree Hall, Alumni & Development Casita, BA/MLS Casita, and the Courtyard. Until further notice, the College of Law campus is open only to Arizona Law faculty, students, and staff.

Exceptions will be limited to those having official business on campus and must be authorized by the Dean’s Office or the Arizona Law COVID Task Force, unless expressly authorized by subsequent sections of this document. Conversely, Arizona Law faculty, staff, and students will limit their interactions with the rest of the UArizona community, as detailed below.

Absent an exception, students may enter the Arizona Law campus only under the following criteria:

  1. Entry for Class. Students may enter the law school during a week (Sunday-Saturday) in which their class or classes are being held within the Arizona law campus and they are scheduled to attend in person under the Red Team/Blue Team structure described in Section 6. Attending classes held online or in person elsewhere on the University campus does not authorize a student to enter the Arizona Law campus.
     
  2. Entry for Clinic. Even if they are not otherwise eligible for entry onto the Arizona Law campus, students who are enrolled in a clinic may access Rountree Hall for purposes of attending essential clinic meetings that must be conducted in-person. These may include meetings with clients or others not part of the College of Law community which cannot be conducted remotely or at another location.

  3. Entry for Work. Student workers may enter the Arizona Law campus during a day in which they are scheduled to work and to perform duties that have been determined incapable of being performed remotely.

These restrictions leverage the relatively insular and nonporous character of the Arizona Law community and physical plant to protect Arizona Law against viral transmission in the broader UArizona community. At the same time and in the same way, the restrictions protect the broader UArizona community from viral transmission at Arizona Law. The restrictions also make possible more robust screening and monitoring of the Arizona Law community, which will generate information about likely infection more broadly and enable a university-wide response.  Any approved individual accessing the College of Law, not from the Arizona Law community, will be subject to the same health questionnaire, temperature check and masking requirement employed by Arizona Law community members.

UArizona has developed an advanced testing plan which includes baseline blood testing that measures antibody (Ab) to SARS CoV-2, the causative agent of COVID-19. An antibody test determines whether one has been exposed to COVID-19 in the past and has developed proteins, called antibodies, against the virus.This free and voluntary testing is part of a research study and is available to all faculty, staff, and students.

UArizona provides free antigen and PCR testing to the UArizona community as well. These tests diagnose an active infection. 

The College of Law plans to implement antigen testing of a cohort of the Arizona Law community volunteers as a research component under IRB approval to monitor the efficacy of Arizona Law protection and mitigation strategies (detailed below and in Appendix A).  This component is not meant to serve as an alternative to diagnosis for those suspected of having illness. Any individual suspected of having COVID will be instructed to seek official viral testing via Campus Health or the equivalent, e.g., Banner.   

MILESTONE: October 1, 2020

 

Information is our safety guard and a primary key to keeping the College of Law campus as safe as possible.

Consistent with the UArizona Returning to Workspaces guidance, all faculty, staff, students, and visitors will be required to complete a daily health screening questionnaire, developed by Arizona Law, before entering the College of Law Campus.

We also recommend that all members of the College of Law participate in the University of Arizona's daily Wildcat WellCheck each day.

To avoid long lines and a potential breach of social distancing, this screening questionnaire will be placed securely on the Arizona Law website. Arizona Law community members will log in, answer the questions, and obtain “clear status” to proceed to campus.

We will also examine the availability of a phone app from UArizona or the development of such an app internally to enhance user flexibility. For visitors and community members who are unable to complete the questionnaire at home, an on-site screening process will be available. See section 4.4.2.

The daily screening questionnaire will include the following questions:

Over the past 24 hours, have you experienced any of the following (beyond your normal baseline health if you have respiratory, gastrointestinal, or other medical condition that would routinely yield a "yes" to any of these questions):

    • Felt ill at all?  (Yes/No)
    • Had a fever? (Yes/No)
      • If you had a fever please specify temperature: ______ (enter number, select degrees F/C)
    • Had chills? (Yes/No)
    • Had a headache? (Yes/No)
    • Had any body aches? (Yes/No)
    • Had a sore throat? (Yes/No)
    • Had any respiratory symptoms including: 
      • Runny nose? (Yes/No)
      • Sneezing? (Yes/No)
      • Coughing? (Yes/No)
      • Bringing up phlegm? (Yes/No)
    •  Had any gastrointestinal symptoms including:
      • Nausea? (Yes/No)
      • Vomiting? (Yes/No)
      • Diarrhea? (Yes/No)
    • Had any new rashes? (Yes/No)
    • Had any new joint pains ? (Yes/No)
    • Any loss or change in your sense of smell ? (Yes/No)
    • Any loss or change in your sense of taste? (Yes/No)

Is anyone in your household or with whom you have had close personal contact in the past 14 days experiencing any of these symptoms beyond their baseline? (Yes/No)

What is your temperature now? ________ (enter number, select degrees F/C)

If you have answered “yes” to any of the above questions or if you have a temperature over 100.4 ℉ (38 ℃) you are encouraged to stay home.  If symptoms and/or fever persist please seek medical attention.

If the Arizona Law Task Force determines that the Arizona Law community is not completing the daily wellness checks (questionnaire and temperature), Arizona Law community members will be directed to take a time-stamped photo of their temperature at home immediately prior to accessing campus as additional evidence of daily compliance.

The procedure for returning to campus after a positive indicator of illness (i.e., an affirmative answer to any daily screening question or positive test for SARS CoV-2) is outlined in section 4.7.

For visitors and community members who have not completed the screening questionnaire and/or temperature check before arriving on campus, an on-site screening kiosk will be available, equipped with a rapid body temperature detection system (Figure 2) and tablet-based questionnaire identical to the one described in section 4.4.1. Arizona Law community members will be prompted to provide an identifying number and visitors will be given a telephone number to call for instructions.

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In addition to the mitigation, testing, and screening described above, Arizona Law will extensively modify its class, library, and workforce schedules, modes of instructional delivery, and physical plant to reduce density and otherwise mitigate the risk of viral transmission on campus.

Arizona Law will also require face coverings, social distancing, and other protective measures for all persons physically present on the Arizona Law campus, including visitors and delivery service providers. The University and the City of Tucson also require wearing face coverings in public.

Enhanced sanitation protocols will be instituted to disinfect high-touch surfaces and regular swipe testing will be employed to monitor the presence of viral material on campus.

Each of these mitigation measures provides an additional layer of protection against the spread of COVID-19 at Arizona Law. All are described in greater detail in subsequent sections.

Arizona Law will build upon UArizona’s baseline antibody testing plan and adopt an additive serial testing plan to more closely monitor the Arizona Law community. Serial testing for COVID-19 will be performed (detailed below and in Appendix A). The purpose of this additional testing will be to: (a) monitor the efficacy of the composite of integrated mitigation strategies being employed by Arizona Law; (b) to limit viral presence and spread in the community; and (c) to obtain greater granularity as to asymptomatic viral presence within the Arizona Law community, eluding screening measures employed. This added testing will be useful to identify infected individuals, emerging trends, or other situations altering the stability of the community.

In addition, Rhinoviruses (e.g. Influenza A/B, RSV, Parainfluenza, Rhinovirus and Adenovirus) will also be tested for in this study. As these viruses will be prevalent in the fall, and causing symptoms and signs confusingly similar to COVID-19, it will be valuable to determine the spread of these in the Arizona Law community, differentiating the common cold and flu from COVID.

Arizona Law has obtained access to supplemental viral antigen testing. All tests selected are reliable, accurate, and easy to perform with regard to sample collection. The technical specifics of each test will be provided in Appendix A.

Eighty individuals from the Arizona Law community will be enrolled as volunteers consisting of : 1L - 18; 2L - 18; 3L - 18; MLS/LLM/SJD - 6; Staff - 10; and faculty - 10. Arizona Law will perform baseline viral antigen tests for both SARS CoV-2 and Rhinoviruses, establishing a “time 0” (baseline) status for all participants. Thereafter, all group members shall be tested biweekly, as depicted on the following timeline:

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All results will be maintained in accordance with privacy and IRB standards. An identity-free tag will be given to all Arizona Law community participating members. Results will be stored in a secured database that has been specifically constructed for this purpose. Results will be monitored by the Arizona Law COVID Task Force to determine emergence of illness.

On an event-specific basis (i.e. an individual tests positive), Arizona Law will adhere to the COVID-19 Workplace Positive Case Notification Protocol and Related Personnel Actions. This guidance provides step-by-step instructions for employees, supervisors, and department heads in the event of a COVID-positive employee in the building. It includes notification protocol to public health, close contacts, facilities management, and everyone in the building. It also includes important privacy guidelines when an employee tests positive. The University has similar protocol and privacy requirements in the event a student tests positive, as noted in the Instructor FAQ. Campus Health also has SAFER guidelines and forms for self-reporting and supervisory reporting of a positive COVID test.

Once medically cleared and back on campus, those individuals who tested positive will return to the serial testing sequence.

Arizona Law adopts UArizona’s COVID-19 Workplace Positive Case Notification Protocol and Related Personnel Actions for faculty, staff, and students returning to campus after failing the daily screening process or receiving a positive test for COVID-19:

  1. Exposure to positive COVID-19 individual, but experiencing no symptoms consistent with COVID-19: Individual may return to work after 14 days of quarantine after remaining fever-free and symptom-free for the duration of that period.
     
  2. Positive COVID-19 test, but experiencing no symptoms consistent with COVID-19: Individual may return to work after 14 days of quarantine after remaining fever-free and symptom-free for that period.
     
  3. Positive COVID-19 test, and experiencing symptoms consistent with COVID-19:
    1. Individual may return to work after fever-free for 72 hours (3 full days) without fever-reducing medication; AND
    2. All other symptoms have resolved (e.g. symptoms are no longer present). If you are unsure if your symptoms are fully resolved, contact your primary care provider; AND
    3. At least 10 days have passed since symptoms first appeared.
       
  4. Not tested or results unknown, but is experiencing symptoms consistent with COVID-19 OR Negative COVID-19 test, but is experiencing symptoms consistent with COVID-19:
    1. No fever for 72 hours (3 full days) without using fever reducing medication; AND
    2. All other symptoms have resolved; AND
    3. At least 10 days have passed since symptoms first appeared.

If any member of the Arizona Law community is experiencing symptoms and has not had a test, they are strongly encouraged to get tested.

All data will be obtained with appropriate IRB and privacy standards maintained. The data will be maintained in a secure database so as to allow serial assessment of the community in case illness develops within the population. This will allow rapid referral to the UArizona contact tracing program and further history inquiry to provide insight as to any evolving disease process and to guide a change in the course of Arizona Law operations. UArizona Test, Treat, Trace Group 7 is developing a data management plan with which Arizona Law will comply.

If UArizona data management resources are unavailable, Arizona Law will have access to a safe, secure and HIPPA-protected database provided by ASAIO (formerly the American Society for Artificial Internal Organs) for maintenance of information that may be utilized to identify progression of disease on Arizona Law campus. The secure ASAIO database is being utilized for the research component of the Plan. Access to the database will be restricted. The database will operate with identity-protected identifiers for general monitoring purposes. Individual identity will only be obtainable by designated members of the Arizona Law COVID Task Force on a health-driven, personal basis if evidence of infectivity or illness emerge. This information will be protected under HIPAA guidelines.

Data from individual daily screening questionnaires will be uploaded automatically to the protected database specifically designed for this Arizona Law project. The database will be queried daily via a specifically designed program to identify individuals who may be ill. A daily report will be generated and made available to the Arizona Law COVID Task Force. As outlined above, if an individual is determined to have evident health issues at risk of COVID, their identity will be determined and they will be privately notified so as to seek additional health scrutiny.

All data will be evaluated serially as well, incorporating weekly building and biweekly supplemental viral testing. Reports will be generated and either the Dean’s Office or the Arizona Law COVID Task Force will communicate the overall “health” of the Arizona Law community.

In addition to preventing transmission of COVID-19 on the Arizona Law campus, the mitigation plan outlined in this section is designed to provide early warning if such transmission takes place. In addition to following protocol outlined in COVID-19 Workplace Positive Case Notification Protocol and Related Personnel Actions, Arizona Law will proceed as follows:

  • If we detect COVID-19 within the building through testing of the physical plant, the Arizona Law COVID Task Force will immediately notify the Dean. The Dean will then determine -- subject to UArizona approval -- whether to temporarily suspend in-person operations until we investigate the source of the contagion. This investigation may include additional testing of faculty, staff, or students. If the source of contagion cannot be identified, the Dean will determine -- subject to UArizona approval -- whether to resume in-person operations. Contemporaneous efforts will be employed to safely disinfect the premises.
     
  • If there is a substantial increase of infection within UArizona or the City of Tucson, UArizona will decide whether to temporarily or permanently suspend in-person operations campus-wide. If operations are not suspended, the Arizona Law COVID Task Force, in consultation with the Dean’s Office, shall assess whether additional mitigation measures are warranted.
     
  • If we detect community spread of COVID-19 within the law school community, the Arizona Law COVID Task Force will immediately notify the Dean. The Dean will then determine -- subject to UArizona approval -- whether to temporarily suspend in-person operations until we can assess whether additional mitigation measures, or whether longer-term suspension of in-person operations is necessary.

This Plan is predicated on a fully reopened UArizona campus. If UArizona is unable to reopen for in-person operations or able to reopen only partially, Arizona Law will adapt this Plan accordingly and in conformity to the latest UArizona guidance. All faculty teaching in fall 2020 should be prepared for the possibility that instruction may need to move fully online on short notice.