Analysis of Bucks County's 2021-2022 School Reopening Guidance and Frequently Asked Questions

This analysis refers to the following document released by Bucks County on August 15, 2021:

“2021-2022 SCHOOL REOPENING GUIDANCE AND FREQUENTLY ASKED QUESTIONS“

The start of school is only a couple weeks away, so Bucks County has just released a clarifying document for school districts to navigate the coming school year with an eye on COVID. As we all know, the Bucks County Health Department (BCHD) has taken a very moderate approach to COVID mitigation, often angering community members who wish for stronger mitigation. Before we get into the document, it is important to note that out of all nearby counties (Bucks, Montgomery, Philadelphia, Lehigh, Northampton, Berks, Lancaster, Chester, Delaware), Bucks County has lower COVID mortality than all except Chester. I believe this is strong proof that the BCHD is not being reckless, but rather being strategic in their resource allocation and general decision-making process.

Introduction

The entire first page of the document is an introduction, and to be perfectly honest I think it is a little bit unnecessarily wordy. That being said, there are some important points to capture from the intro:

“…as of the date this memo was issued, Bucks County as a whole averages 9 cases per day of school-aged children.“

BCHD does not wish to put out any mandates, but rather seeks to provide guidance in an advisory role.

BCHD firmly plants a flag in the ground by saying that the “effects of ongoing COVID-19 mitigation efforts have led to significant learning loss, mental health issues, and social adjustment difficulties in many students.” We will come back to this later.

The intro goes on to say “Both the Commissioners and the BCHD are aware that a full return to school is a critically important issue for the mental health and educational development of our children.” This is important to note, as the top of the document is addressed from not just Dr. Damsker but also all three of the Commissioners. They appear to be a unified team.

Frequently Asked Questions

What is the BCHD’s position on CDC guidance?

“The BCHD recognizes that school districts must review guidance from federal, state and local health authorities in their decision-making process. In addition to broad CDC guidance that attempts to cover the needs of all 50 states, and guidance from the Pennsylvania Department of Health for the entire Commonwealth, schools in Bucks County have the opportunity to work collaboratively with the BCHD, as the local health authority, to incorporate specific localized guidance based on their current data. Even within Bucks County itself, factors such as population density, case counts, and vaccination rates vary, with some areas in the County more impacted by COVID-19 than others. This variability within our County further illustrates the point that a one-size-fits-all approach to disease mitigation may not always be the most prudent approach at any level. Working with the BCHD, school districts can analyze data in order make locally-informed decisions. Indeed, it was through this data-based collaboration and local perspective, which allowed for our successful return to in-person school last year. The partnership between the BCHD and school districts resulted in near daily conversations and consultations that allowed for both safe classroom environments and best practices for mitigation. This collaboration will continue throughout the upcoming school year and beyond.“

Right out of the gate, BCHD makes the argument that local guidance, informed by local data, is superior to CDC guidance which attempts to cover the entire country. The document points to the success of school districts that opened at the beginning of last year as proof that local coordination between districts and the BCHD is optimal. That’s a clear shot at the districts who chose to ignore the BCHD last year and stayed closed. Today, it is universally understood that was a poor move and should not have happened. It shouldn’t happen this year, either.

What is the BCHD’s position on vaccines?

“The BCHD unequivocally recommends that everyone eligible get vaccinated. The BCHD knows that vaccines are safe, effective, and the best tool we have to mitigate COVID-19. Vaccines are proven to reduce symptoms and substantially reduce death and hospitalizations due to COVID-19. The existing data, both here in Bucks County and nationally, show the overwhelming majority of people getting seriously ill from COVID-19 are those who are unvaccinated. We recommend that school districts consider mandating vaccination for all school staff and teachers, a position supported by National Education Association (NEA) and American Federation of Teachers (AFT) nationally. Similar requirements have existed, and been successful, for decades.“

Pretty standard response as I think we all would expect from a health department. But two points stick out to me:

It credits vaccines as being “proven to reduce symptoms and substantially reduce death and hospitalization due to COVID-19.” What’s interesting is what they leave out: transmission. At this point it is pretty widely accepted that the vaccine is not reducing transmission (example: Iceland, which is over 90% vaccinated yet currently has more COVID cases than at any point during the pandemic). The fact that BCHD recognizes what the vaccine is good at (reducing symptoms) and what it’s not good at (reducing transmission) is important. It quietly says that vaccines protect the person who takes them; they don’t necessarily protect others around that person.

The teachers union thing is very bizarre to me. Is this a bluff? It feels to me like something that is inserted as leverage to counter any anger that would come from the hardcore COVID enthusiast side. Kinda like throwing them a bone? Either way, ReOpen Bucks has always opposed mandates and that will never change.

What is the BCHD’s position on masks/face coverings in schools?

“For the start of the school year, we recommend that at a minimum, schools should adopt a “mask-optional” policy. Moving forward, the BCHD only recommends the use of Targeted Temporary Mitigation (TTM), wherein school districts consider making mitigation decisions in consultation with the BCHD based on their local data and for specific situations. “Targeted” means it’s not a one-size-fits-all approach, and instead, is in response to individual situations and needs. Mitigation measures should be crafted in order not to affect healthy, non- exposed individuals, when possible. “Temporary” means that all mitigation be time limited to meet the needs of the specific issue at hand, rather than imposed without a defined end. To help inform their TTM decisions, the BCHD will supply each school district with data, such as current COVID-19 cases broken down by zip codes. The BCHD may recommend TTM efforts that include actions such as time-limited mask/face covering requirements for children under 12 years of age, or briefly requiring masks/face coverings for individuals in elementary school classrooms in which there are known outbreaks of multiple cases. The TTM approach mirrors similar and successful mitigation efforts supported by BCDH in schools for decades in response to various diseases. While those diseases and COVID-19 present different challenges, TTM efforts remain the gold standard from a public health perspective. Public health authorities strive to limit their response to the least restrictive action for the least period of time in order to achieve the desired outcomes for public health. Additionally, the BCHD supports enhanced TTM efforts in clinical and healthcare-like school settings, and will discuss further recommendations for those situations with school entities.”

Here is where things start to get interesting: the ever-contentious mask debate. The answer starts with a very firm “schools should adopt a ‘mask-optional’ policy“. It then goes on to define what I think is a brand new term (at least, I’ve never heard it before): Targeted Temporary Mitigation (TTM). The idea of making mask mitigation targeted (“in response to individual situations and needs“) and temporary (“time limited“) is something I can get behind. ReOpen Bucks has said from the beginning that mitigation efforts should always be narrow in scope in order to maintain trust between the people implementing the mitigation and the people affected by it. Open-ended and broad measures tend to cause more division than narrow, focused ones.

The problem here is that there are some vague terms being used. The BCHD may recommend TTM masking in a classroom “in which there are known outbreaks of multiple cases.” So…two? Or three? What does that mean? Obviously, by December there will be many classrooms in Bucks County with more than one COVID positive student. That does not mean that there was any in-classroom spread; it just means that there is high community prevalence. Does the term “outbreaks of multiple cases” refer to situations where the spread demonstrably occurred in the classroom? What about when a handful of classmates catch COVID at a birthday party outside of school? I think some clarity around the term “outbreak” is warranted. It should be limited to situations where multiple students catch COVID inside the classroom (an occurrence that almost exclusively occurs as a result of the teacher transmitting to many students in one day).

What is the BCHD’s position on masks/face coverings on school buses?

“The CDC has issued an order that requires masks/face coverings to be worn on all forms of public transportation. Each school district must work with their solicitor to interpret this order and its applicability.“

The BCHD knows that the CDC order to mask on school buses is actually illegal, as there is no federal jurisdiction over school buses. They do not cross state lines or the nation’s border. Every school district solicitor in Bucks County knows this as well, but many of them are only interested in playing to Democrat talking points. Unfortunately, Democrat-controlled school boards will likely adopt a bus mask requirement, as it is politically expedient for Democrats to obey the CDC even when they know that the order is unlawful.

“The CDC’s order relies upon 42 U.S.C. § 264(a) as the basis for its authority; however, that provision only applies to actions taken to prevent the spread of diseases 1) “from foreign countries into the States;” or 2) “from one State…into any other State.” 42 U.S.C. § 264(a). Additionally, the order also cites a regulation (42 CFR 70.2) for authority; however, that regulation specifically only applies to “interstate” issues, rather the “intrastate” matters. In other words, the CDC does not have the power to regulate any actions incurring entirely within a single state.“

What is the BCHD’s position on sick or symptomatic students/staff in the classroom?

“The BCHD strongly recommends school districts consider that any student/staff exhibiting fever or multiple symptoms should be excluded from school until those symptoms have resolved and are fever-free for 24 hours without medication, in accordance with existing protocols and best practices. School districts may also consider utilizing TTM in other appropriate situations, such as a temporary face covering for an individual displaying symptoms while in school. The BCDH is committed to providing more detailed guidance to support school nurses on these issues throughout Bucks County schools.“

So this one is pretty standard–people should stay home when they’re sick. I don’t think anyone would disagree with that. This was my primary (in fact, ONLY) policy for Bucks County Sports Association: stay home when you’re sick, come play when you’re healthy. The second sentence is a bit strange to me. I believe this sentence was intended to cover individuals who develop symptoms while at school. If so, the word “displaying” should have been “developing“.

Bottom line: sick people should stay home until they are healthy.

What is the BCHD’s position on contact tracing and notifications?

“The BCHD continues to focus its limited resources by contact tracing in the highest-risk settings that include congregate care facilities, corrections, and nursing homes. However, we strongly recommend that school districts urge parents to report their child’s confirmed case of COVID-19 to the school nurse or staff designee, and for districts to send notification to the parents of all students in that child’s classroom, specifically in schools with unvaccinated children under the age of 12. The BCHD will closely monitor COVID-19 and its variants, and TTM may include a return to additional contact tracing for a period of time if it becomes necessary.“

Since the end of last year, BCHD has moved to put its contact tracing resources where it matters: nursing homes. While many COVID enthusiasts are appalled at the idea of NOT contact tracing schools, the fact is that contact tracing is a zero-sum game: there is only so much to go around. When it comes to COVID, schools are extremely safe; nursing home are not. It makes perfect sense that BCHD will continue with this policy.

I am slightly disappointed in the strong recommendation to notify classrooms of a confirmed case of COVID-19. I believe that this will lead to continued, unnecessary hysteria as November/December will see tons and tons of notifications, causing panic in the community. That being said, it seems to me that Team Reality folks will simply not get their kids tested and not care too much if they get a notification. Team Apocalypse folks will be testing their kids non-stop (so they will be the ones reporting positive results) and they will also be the ones to respond frantically to a notification. So as long as the school, the district, and the BCHD are able to maintain composure and not freak out, then the policy to notify won’t be too big of a deal. But I still think that it is unnecessary fuel for hysteria.

One part of the notification recommendation that jumps out at me is that it qualifies the proof required. By saying “we strongly recommend that school districts urge parents to report their child’s confirmed case of COVID-19“, they are essentially saying that they want to know about positive test results, and that’s it. If you fall into the bucket of people who don’t want to test incessantly, then you would not report anything to the school, because you just keep your kid home when he is sick–you don’t test. So if your kid’s case is not confirmed, then there is nothing to report. I feel that this will definitely be implemented with varying methodologies in various districts, and parents will be confused as to what should be reported and what shouldn’t. School boards must be very specific if they adopt this recommendation.

What is the BCHD’s position on isolation and quarantine?

“The BCHD strongly recommends that school districts consider requiring any symptomatic students/staff who test positive for COVID-19 be excluded from school until symptoms have resolved and they are fever-free for 24 hours. Infectiousness peaks around the time of symptom onset and declines quickly during the first several days of symptoms. Schools may then elect to require a positive individual to wear a mask/face covering upon return to school through the 7th day from symptom onset, if applicable.

–

Individuals who test positive but are fully asymptomatic should wait at least 3 days from the test date prior to returning to school in order to ensure they are not just pre-symptomatic (about to become symptomatic.) Based on BCDH case investigations throughout the pandemic, COVID-19 transmission within a household was very unlikely from individuals who, as the first known positive case in the household, remained asymptomatic through the course of the infection. As such, the BCHD believes individuals who have not yet developed any symptoms more than 3 days from a positive test can safely return to school. Schools may then elect to require a positive individual to wear a mask/face covering upon return to school through the 7th day from the test date.

–

Fully asymptomatic Individuals with a known non-ongoing (i.e. not in their household) exposure to COVID-19 may continue in school normally unless any symptoms develop, in which case they should either remain home, or be evaluated by a school nurse if at school.

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Fully asymptomatic individuals with an ongoing household exposure to COVID-19 should be required to wear a mask/face covering at school for a minimum of one week from the symptom onset of the household member. For fully asymptomatic individuals in households with multiple positives, the mask wearing period may be extended. If any symptoms develop during this timeframe, the individual should be immediately excluded.”

This is where things get a little bit tricky. This is a confusing section, to be sure. Let’s start by breaking down the four primary groups that are described here:

Individual who is symptomatic AND tests positive
Individual who is asymptomatic AND tests positive
Individual who is asymptomatic AND has a non-ongoing exposure
Individual who is asymptomatic AND has an ongoing exposure

Now, right off the bat I notice that this immediately creates very different worlds for people who test their kids and people who don’t. Let me explain one by one…

Individual who is symptomatic AND tests positive – People who aren’t tested can never be in this bucket.
Individual who is asymptomatic AND tests positive – People who aren’t tested can never be in this bucket.
Individual who is asymptomatic AND has a non-ongoing exposure – This affects people who test and people who don’t test exactly the same, but really has no impact on anything, because the guidance is to just continue normally.
Individual who is asymptomatic AND has an ongoing exposure – Families that don’t get tested won’t have family members test positive, so no one in the family can be in this bucket.

At the end of the day, it seems to me like this guidance is meant to provide a mutually-agreeable solution to COVID enthusiasts (who will be testing themselves and their kids all the time) and Team Reality folks (who won’t). At the end of the day, the real emphasis seems to be on: stay home when you are sick. Get tested if you want to get tested, and don’t if you don’t. That choice will determine whether or not your family experiences certain mitigation efforts.

Again, this section is a bit confusing and has a lot of moving parts, but the general principle seems solid. Let’s ALL stay home when we are sick, and let’s choose whether or not we want to play the testing game and be affected accordingly.

“The BCHD supports any school district efforts to socially distance when feasible, while still prioritizing the importance of in-person instruction. There is no need to limit classroom capacity at this time.“

Social distancing is so last year.

What is the BCHD’s position on testing?

“The BCHD is committed to providing assistance, resources, and funding to support rapid testing protocols for symptomatic individuals for stakeholders to keep schools open.“

Very important point here, and one that every single Bucks County School Board will have to grapple with. “BCHD is committed to…testing protocols for symptomatic individuals…“. The word “symptomatic” right there literally changes everything about this document. This document is not a referendum on masks, or social distancing, or contact tracing. This document is a referendum on keeping kids in school. When you test an asymptomatic person, you don’t really gain much in the fight against COVID, but you DO put that person in situations where they may miss school or some other event. The BCHD is tacitly telling everyone in Bucks County that the way we keep our kids in school is to not test healthy kids.

Where can school districts, parents, and stake holders access pertinent data?

“Please visit buckscounty.gov and click on the COVID-19 button. For any data not found on the site, the BCHD will work with school districts to provide additional information they can use to establish TTM policies. The BCHD encourage school districts to share data with the community as appropriate to empower parents to make informed choices for their children.“

Not much to say here; pretty standard stuff.

Overall Analysis

The more that I go back and read the document, the more I become struck by one incontrovertible fact: while the community is currently divided on the issue of masks, the BCHD is simply trying to keep classrooms open as much as possible. I am a bit disappointed, as I remain convinced that school mask requirements accomplish absolutely nothing in the fight against COVID. But despite that disappointment, I can respect that the potential mask requirements outlined by this document are targeted and temporary in nature, in alignment with this new TTM strategy. I can get behind that, especially with a health department director that I trust to have the community’s best interest at heart. I am especially moved that the introduction speaks specifically to the loss of learning and unfolding mental health crisis as legitimate public health issues unto themselves. I couldn’t agree more with the notion that there is more to life than COVID.

At the end of the day, this guidance and FAQ leave mitigation decisions firmly in the hands of every district. That means that some districts will do this, some will do that. With 13 districts in Bucks County (plus Souderton Area), we will likely have a whole spectrum of policies when school starts in a couple weeks.

ReOpen Bucks will continue to oppose mask requirements in any and all settings, and we trust that in a few short months we will be able to compare mask-optional school districts to mask-required ones. We will compare case prevalence in the schools and in the local community (zip code granularity), and we will finally have an answer as to whether or not masks help. I firmly believe that we will see no difference at all, and if so, then I expect every single School Board Director in Bucks County who votes for a mask requirement to resign. The BCHD has told you how it ought to be done, and you are choosing to ignore them. You are choosing to ignore the guidance of the top public health doctor in Bucks County. If the results show that it was all for nothing, then you have an ethical duty to resign. If I am wrong, then I will certainly apologize publicly, but I am not the one currently ignoring the top public health doctor in the county.