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January 12, 2021
Fairfax County School Board
8115 Gatehouse Road
Falls Church, VA 22042
Dear Chairwoman Anderson, Superintendent Brabrand and Honorable Members of the Board,
On behalf of our thousands of members and supporters, we write to share our concerns with the FCPS Return to School Plan. We all share a deep desire for students, staff and families to have confidence in the implementation of the plan. We urge FCPS to take a significant number of steps in order for this to occur.
Establish clear, consistent health metrics for controlled community spread of COVID19: We are deeply concerned and disappointed that FCPS changed the Fairfax County test positivity rate threshold from 5% to 10%. This is a significant change which puts FCPS students and staff, especially those in county-wide special education programs and centers, at serious risk. Compared to neurotypical people with COVID-19, individuals with intellectual and developmental disorders are three times more likely to die if they have the virus. Further, studies show that children over 10 have the same infection rates as adults - this cannot be ignored as a “kids don’t get COVID” concern. While VDH and the CDC list it as acceptable to educate select cohorts at or below 10% positivity rate, the Superintendent and School Board have the discretion to opt against this. Other large school systems, such as Baltimore and Boston, are using 5% as their cutoff metric. We are also concerned that FCPS has not established ceiling thresholds for Groups 1 and 2 to transition back to distance learning. We are concerned that the FCPS threshold for Group 3 is a Fairfax County positivity rate greater than 10% for a full 7 consecutive calendar days. These metrics aren’t safe. They will contribute to the spread of COVID-19 in our community.
Consistently implement and comply with FCPS mitigation strategies: FCPS staff, students and families report unsafe conditions, including some staff not being provided with PPE (including in appropriate sizes) or schools running low, inadequate supply and installation of plexiglass dividers, staff and students not following social distancing protocols or staff and students without a medical exemption not wearing masks by choice or by circumstance of the student population, staff not receiving training on cleaning materials and procedures for health and safety protocols, no public tracking of supplies or when cleaning occurs, delays in contact tracing and insufficient space in high school buildings to accommodate large cohorts while maintaining 6 feet of social distancing in classrooms.
Adopt a clear cutoff metric for all students and staff to be in school buildings. If COVID19 cases exceed these metrics, FCPS should “dial back” and return all students and staff to 100% virtual learning. The metric should be: A demonstrated decline in new cases and hospitalizations for at least 14 days, a positivity test rate of less than 5%, a transmission rate of under 1.0, and testing, contact tracing, and isolation capacity in Fairfax County that is sufficient to support moving from remote to in-person instruction.
Establish a centralized reporting system: Despite consistent advocacy from stakeholders for many months, FCPS has not established a centralized confidential reporting hotline or email address where safety and protocol concerns may be reported, tracked and analyzed.
Establish independent audit teams: FCPS should establish independent audit teams composed of staff, families, FCHD and other stakeholder groups to ensure these conditions are being met and compliance is being done with fidelity. This includes unscheduled and unannounced observations as we have received reports of administrators notifying classroom staff of imminent visits from auditors. Further, reports have been made that audit teams are touring facilities on Mondays when no students are in school on Mondays.
Provide clear and consistent communication: FCPS staff, students and families report that the notification of COVID-19 cases is not occurring consistently or in a timely manner due to ineffective or unclear unified direction to school administration from FCPS and the Fairfax County Health Department (FCHD). Further, the numbers of COVID-19 cases on the FCPS dashboard do not match the notifications that are being sent out by schools. Additionally, inconsistent notifications are sent from schools that house multiple programs (e.g. high schools that house Academy programs are not notifying Academy families of positive cases in the main high school population, and vice versa). Staff and families remain unclear about the definitions of the various cohorts and often cannot identify the cohort in which they belong. In addition, staff report that students have been misclassified in order to be in one of the FCPS groups currently eligible for in-person instruction.
Physical distancing: Give students and staff specific instructions and training in order to correctly implement maintaining a minimum of six feet distancing at all times. This includes settings such as, but not limited to: waiting for the school bus, entering/exiting/sitting on the school bus, school entrance and exit procedures, hallway passage, eating, recess and other physical activities, and within the classroom. Where physical distancing is not possible due to the nature of the student population (e.g., IDS, PAC, Center-based, and CSS programs), FCPS should provide medical-grade N-95 masks and PPE clothing in the correct sizes.
Cleaning and disinfecting protocols: FCPS must provide training for all staff on health and safety protocols. This training must establish clear expectations for when and how cleaning must occur. All staff, including custodians, must be trained in the use of disinfecting products (e.g. Virex, hand sanitizer, etc.) and the manner in which they must protect themselves when using these products. Every instructional and common space must be equipped with hand sanitizer and necessary disinfecting products. There must be public posting of when cleanings occur, such as what one finds in a public restroom. FCPS must provide sufficient custodial staffing to implement these required cleaning and disinfecting protocols.
Adequate school ventilation and building systems: School ventilation and building systems must be inspected, repaired and maintained in accordance with ASHRAE and other groups such as the National Energy Management Institute, to allow for maximum outside air intake and installation of high efficiency filters (at minimum MERV 13) when physically possible. FCPS must train maintenance staff on these protocols and make both the protocols and related service records publicly available.
Personal Protective Equipment (PPE) and Face Coverings: Ample supply of promised PPE for high-risk staff and programs must be made immediately available, readily accessible, and abundantly maintained on site. FCPS must train all staff and students (beyond the overly basic video shown to staff) on proper technique to don, doff, and dispose of PPE, as well as proper cleaning procedures for reusable face coverings. Staff and students need clear guidance on how they should proceed when they observe FCPS PPE policy being violated.
Rigorous tracking and tracing: FCPS and FCHD jointly promised widespread, accessible, and frequent testing for students and staff; this has not occurred. FCPS must enforce their own policy that students and staff who display symptoms consistent with COVID-19 infection must quarantine and only return to school once they test negative for COVID-19. FCPS must publicize these policies, in multiple languages, to all staff, students and families. Students who are unable to wear masks to protect against COVID should be tested more frequently to increase safety.
Training for all current and evolving procedures must be scheduled prior to implementation start date to allow for testing and practice of the procedures at every school.
All of the aforementioned policies and procedures must be clearly documented, widely publicized and readily accessible together on the FCPS website in one location and together in paper form at every school and FCPS building to be kept in the main office for reference. This documentation must take into consideration the language, culture, and reading level accessibility of the FCPS community. Finally, it must be distributed to staff before being distributed to the public to allow staff time to review and seek clarity, where needed, so that staff will be able to respond correctly to questions from the public.
We appreciate your partnership in taking these critical steps immediately to protect the health and safety of FCPS students, employees, and our community at large.
Sincerely,
FCFT
Fairfax County SEPTA