Dear Governor Ducey, 

As the executive director of the organization representing Arizona’s 230-plus public school districts and their locally elected governing boards, I am writing to you today to urge a rigorous, science and data-based approach to school reopening in Arizona. ASBA appreciates your action of delaying the resumption of in-person instruction until August 17th, and appreciates the complexity of decisions regarding education, public health, and other sectors of the economy that must be made. 

We also appreciate the measures that have been taken to stabilize school funding and bring some level of predictability to school district budgets in FY2021. Further, although it imposes a rather large administrative burden on school districts and charter schools alike, we recognize that the Enrollment Stability Grant program designed by your office will alleviate pressure on the state General Fund. These policies are good for schools and good for Arizona, and we thank you. 

However, as you yourself discussed last week, the conditions in our state are not yet favorable to safely resume in-person activities on our school campuses. Communities and school staff are also divided on the issue of when reopening is advisable, both within districts and throughout the state. ASBA holds local control as a core value, and while we adamantly believe that educational decisions should be local, when it comes to public health decisions, a centralized framework for managing risk is helpful. School officials are not public health officials and desperately need guidance from those professionals closely following the science of the pandemic. ASBA supports state efforts to increase diagnostic testing and timely test processing, which is critical to ensuring the reliability of any criteria used for reopening schools 

There are three areas we would urge you to consider when formulating your future school plans both to make it easier for various areas of the state to open schools as conditions dictate and allow local officials to manage conditions on the ground: Prescribe criteria for reopening that can be applied on a county-by-county basis, grant explicit authority for districts to maintain social distancing whenever students are at school, and direct the Department of Health Services to define a protocol that includes contact tracing if it is discovered that a staff member or student reports a positive COVID-19 test result. 

Criteria for Reopening 

ASBA feels that establishing a date-specific approach to reopening is not practical when the trend of cases across Arizona is not known. We wish to avoid a repeat of the anxiety being experienced right now as August 17th looms as a date on the calendar. Instead, we urge you to establish gating criteria that allows schools to resume in-person instruction on a county-wide basis without having to wait for cases in more populous counties to be brought under control. 

In the White House Guidelines for Opening Up America Again, schools are recommended to remain closed until the phase 2 criteria have been met. We would propose that if the CDC phase-specific thresholds for phase 2 have been met, county health officials may allow schools to reopen to students. These criteria would include (simplified to account for phase 1 and 2): 

  • New Cases: A downward trajectory of documented cases of COVID-19 for at least 28 days. 
  • Percent Positive: A decrease in percentage of positive COIVD-19 tests for at least 28 days while maintaining a flat or increasing test volume. 
  • Robust Testing: Percent positive cases are less than/equal to 15% for at least 14 days consecutive days, and median time to obtain test results is less than or equal to three days. 

These criteria will give the community a degree of confidence the spread of COVID-19 in the community is reasonably well-known and the virus is not spreading outside the visibility of public health officials. Because we are not qualified to comment on metrics related to hospitalization for COVID/influenza-like illness or crisis standards of care, and these metrics are lagging indicators of spread, we recommend a proactive approach outlined by the CDC and public health experts. 

With regard to the requirements of EO 2020-41, we believe that if communities have not met the prescribed metric for in-person instruction, requirements to offer “free onsite learning” for students in a hybrid program should continue to be suspended until such time as in-person instruction can resume. They should also be suspended in the event a positive case or resurgence of the virus causes school closure. 

Grant Explicit Authority to Maintain Social Distancing 

The intent of Executive Order 2020-41 is clear: to provide access to underserved students or students whose parents/guardians are essential workers. We agree. However, districts have interpreted the “free onsite learning” provision in a number of different ways and are rightly concerned that if they are not able to limit the number of students on their campuses, the order could undermine their ability to enforce proper social distancing. If the intent of this requirement was to leave some ability for interpretation at the local level, we would appreciate an explicit direction that school districts will determine implementation of this requirement consistent with maintaining appropriate social distancing within facilities available to the district. 

Protocol for Positive COVID-19 Test Result 

School district administrators and board members would like nothing more than to reopen schools. Life is infinitely easier for everyone involved if schools function according to their normal routines. School leaders also have an obligation to keep their students and staff safe from harm. Unfortunately, those two ideas currently are in conflict. As leaders, we cannot in good conscience open a school without precautions if we know that it is not safe. 

The final area to consider is what schools will be required to do and/or should do when it is discovered that a student, staff member, or community member has tested positive for COVID-19. The CDC recommends a short-term dismissal of 3-5 days to allow for the campus to be cleaned and sanitized, during which time schools can return to distance learning. 

Unlike private businesses, students have a right to be present in the educational setting. Therefore, it would be helpful to have direction from the ADHS on this issue. Typically, students return to school from being sick after they “feel better,” but that has proved to be an inaccurate indicator for COVID. Schools would benefit from solid public health advice on this topic. For example, the county health departments recommend a person/student should self-isolate and not return to work or class for at least ten days following a COVID-19 test if they are asymptomatic, or for at least ten days since first symptoms and 72 hours until a fever has resolved and other symptoms have improved.  

We are acutely aware that each phase of school reopening, whenever it arrives, comes with more questions. It is the obligation of our membership to decide many of them at the board table, and we accept that. However, as noted before, school leaders are not public health officials, and guidance from public health in this area is not only invaluable, but also the most prudent course. While school leaders want to “follow the science,” they first must have accurate, locally specific information as to what the science is at that particular moment. 

Since the beginning of this pandemic, ASBA has offered to work in partnership with your office to arrive at the best practical policies that will serve the needs of the state and preserve the safety of students and staff, and I do so again here. If I or my team can be of any assistance to you or your staff during this time, please do not hesitate to contact me. 

Sincerely, 

Dr. Sheila Harrison-Williams 

Executive Director 

Arizona School Boards Association 

 

cc: Hon. Kathy Hoffman, Superintendent of Public Instruction 

Dr. Cara Christ, Director, Arizona Department of Health Services