Higher Education Law Report
Update on Ebola For Colleges and Universities
October 20, 2014Back in September, we reported that the Center for Disease Control (CDC) had issued guidance to colleges and universities on how to respond to the spread of Ebola in West Africa. The guidance included suggested precautions with respect to (a) study abroad programs, research and other education-related travel to the region, and (b) individuals arriving on campus from the region or otherwise known to have been exposed to Ebola. Given the ongoing concerns and availability of more guidance and information relating to Ebola, we are offering this update with our own recommendations to ensure that you have current information and consider the aspects of this health concern from the perspective of a college or university. According to the CDC, a person infected with Ebola is not contagious until symptoms appear. Symptoms may appear anywhere from 2 to 21 days after exposure to Ebola but the average is 8 to 10 days. The signs and symptoms of Ebola typically include:
• Fever (greater than 38.6°C or 101.5°F) • Severe headache • Muscle pain • Vomiting • Diarrhea • Stomach pain • Unexplained bleeding or bruisingDiagnosing Ebola in a person who has been infected for only a few days is difficult because the early symptoms, such as fever, are not specific to Ebola infection. However, if a person has symptoms of Ebola and had contact with blood or body fluids of a person sick with Ebola, contact with objects that have been contaminated with blood or body fluids of a person sick with Ebola or contact with infected animals, the individual should be isolated and public health professionals notified. Samples from the individual can then be collected and tested to confirm infection. The CDC’s recommendations for student health centers in responding to potential Ebola exposure and managing individuals presenting with symptoms consistent with Ebola disease are the same as those for other US health care workers and settings. As a planning step, colleges and universities should review and consider utilizing the American College Health Association Emergency Preparedness Planning Considerations for College Health Centers Regarding Ebola Virus Disease:
1. Is your campus emergency response plan up to date so it can be activated if needed to respond to a case of Ebola on campus or in the local community? Is it coordinated with the local public health department on a community response to a case of Ebola?
2. Does your campus have a communications plan and team in place to respond to the communications need if a case were to emerge on campus, in the community, or at another institution? Is the communications plan coordinated with the local community so that your campus would be informed if a case emerges in the community, allowing communication to students and parents?
3. If the public health department orders a quarantine for a high risk exposure, does the campus have a location and plan to provide food and clothing to a quarantined person? Does the campus have a mechanism (qualified contractor) in place to dispose of waste?
4. Is the student health center screening all patients for travel in the past 21 days? Are there plans in place to quickly respond to an ill student with a travel history from an Ebola affected area? What about other emerging pathogens?
5. Is there a mechanism to identify and contact students, faculty, and staff who are returning to campus from an Ebola affected area and refer appropriately to the public health department for monitoring?
6. Who is responsible for monitoring individual and group institutional travelers? Is there a policy and/or mechanism in place to restrict travel based on the CDC travel warning?In keeping with these recommended planning steps, institutions should consider the following actions:
- Ensure that student health center staff are aware of exposure risks, signs and symptoms of Ebola and are prepared to follow recommendations in the CDC Health Advisory: Guidelines for Evaluation of US Patients Suspected of Having Ebola Virus Disease.
- Consider providing information to the campus community with recommendations for people who have recently arrived from countries where Ebola outbreaks are occurring and provide specific Ebola education to all people who have recently arrived from countries where outbreaks are occurring in accordance with the screening procedures.
- Continue to monitor the countries of concern in terms of Ebola outbreak. Here are the current CDC travel notices related to Ebola even if travelers do not plan to be in contact with people infected with the virus:
Warning - Avoid nonessential travel: Ebola in Liberia, Guinea and Sierra Leone Alert - Practice enhanced precautions: Ebola in Democratic Republic of the Congo Watch - Practice usual precautions: Ebola in Nigeria
- Based on current travel notices consider making adjustments to programs for the current semester and upcoming spring semester which would involve travel by students and faculty to these regions.
- Identify students, faculty, and staff who have been in countries where Ebola outbreaks are occurring within the past 21 days and conduct a risk assessment with each identified person to determine his or her level of risk exposure (high- or low-risk exposures, or no known exposure). Consult the CDC’s algorithm for evaluation of a returned traveler:
The following steps are consistent with current CDC guidance:
- If the student, faculty, or staff member has had NO symptoms of Ebola for 21 days since leaving a West African country with Ebola outbreaks, they do NOT have Ebola. No further assessment is needed.
- If the student, faculty, or staff member has had a high or low-risk exposure, state or local public health authorities should be notified, and school officials should consult with public health authorities for guidance about how that person should be monitored. Anyone with a potential exposure should receive thorough education about immediately reporting symptoms and staying away from other people if symptoms develop.
- In the event that a student, faculty, or staff member who has had a high or low-risk exposure develops symptoms consistent with Ebola, the person should be medically evaluated while following recommended infection control precautions. Guidance is available in the CDC Ebola Virus Disease Information for Clinicians in U.S. Healthcare Settings. Public health authorities should be notified.
- If the student, faculty, or staff member displays no symptoms and presents no known exposure risk, institutions are advised to instruct the individual to self-monitor through temperature and symptom reporting until the end of the 21 day period, and to report immediately if symptoms appear.
Note that the CDC is still not recommending that colleges and universities quarantine individuals based solely on travel history. The system presently relies on individuals, including college students, to self-monitor for the onset of symptoms and to take immediate steps to self-report. This raises the questions as to whether the self-monitoring/reporting system is reliable enough or whether other steps should be considered to protect the campus community. Reasonable minds may differ as to whether all return travelers are reliable enough to self-monitor without some other level of mandatory oversight. One option, for example, may be for the Campus Health Center to actively participate in the monitoring of individuals to ensure accurate assessments and timely reporting and action if the individual develops symptoms.
- In the event that a potential case is identified, isolate the individual pending diagnostic testing.
- Although not a full list of precautions, student health center clinicians should be sure to follow these steps when caring for someone who is sick or may be sick with Ebola:
- Separate the sick individual in a private room with its own bathroom.
- Use proper infection prevention and control measures; standard, contact, and droplet precautions are recommended if Ebola is suspected.
- Wear the right personal protective equipment (PPE), including masks, gloves, gowns, facemask and eye protection, when entering the patient care area. Before leaving the patient area, carefully remove PPE and make sure not to contaminate skin and clothing. Dispose of PPE as biohazard waste.
- After removing PPE, wash hands using soap and water (preferred) or an alcohol-based hand sanitizer containing at least 60% alcohol. Use soap and water when hands are visibly dirty.
- Notify local or state health department immediately if Ebola is suspected. The health department can provide additional guidance regarding medical evaluation or testing, if indicated.
- Follow protocols for cleaning and disinfecting reusable medical equipment and proper disposal of needles and other disposable equipment.