Special Bulletin For Private Education: New Travel Restrictions Announced By The President, The CDC, and The State Department

CATEGORY: Special Bulletins
CLIENT TYPE: Private Education
PUBLICATION: LCW Special Bulletin
DATE: Mar 13, 2020

Earlier this week, LCW issued guidance to schools regarding trips in light of the Coronavirus pandemic (COVID-19).  LCW also issued guidance regarding schools’ ability to send students and employees home based on their recent travel to countries that have Level 3 or Level 2 Travel Notices from the Center for Disease Control (CDC).

Since we issued this guidance, additional travel restrictions and recommendations have been issued by the President, the State Department and the CDC.  Additional Level 3 Travel Notices have been issued due to the COVID-19 pandemic, and the CDC has determined that all global travel falls within the Travel 2 Notice category.

A.       President Trump Announces a Ban on Travel between the United States and Europe

On March 11th, President Trump announced that there will be a travel ban on all travel between the United States and Europe, with the exception of travel to and from the United Kingdom.   The travel ban will go into effect on Friday at midnight, and will be in place for the next 30 days.   The government has since clarified that these restrictions apply only to people who are not U.S. citizens, who in the past two weeks have been in European nations that are part of the Schengen Area: Austria, Belgium, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherland, Norway, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden and Switzerland.  American citizens are exempt from these restrictions but there will be a limited number of airports for returning citizens where screenings will take place.

B.      The State Department Has Issued a Level 3 Global Health Advisory

On March 11, 2020, the State Department issued a Level 3 Global Health Advisory recommending that U.S. citizens reconsider travel abroad due to the global impact of COVID-19.   The State Department explained that “[m]any areas throughout the world are now experiencing COVID-19 outbreaks and taking action that may limit traveler mobility, including quarantines and border restrictions. Even countries, jurisdictions, or areas where cases have not been reported may restrict travel without notice.”  On March 9, 2020, the State Department issued country specific information related to COVID-19. In light of the State Department’s advisory, LCW recommends that schools cancel or postpone upcoming trips that involve international travel.

C.      The CDC Has Issued Additional Level 3 Notices

The CDC issued new guidance stating that Europe is experiencing widespread sustained transmission of COVID-19.  The CDC has issued additional Travel 3 Notices, recommending that travelers avoid all non-essential travel to the following countries in Europe:  Belgium, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Lithuania, Liechtenstein, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden, Switzerland, Monaco, San Marino, Vatican City.

The CDC states that travelers returning from the any of the above countries in Europe must stay home for 14 days after returning from travel, monitor their health, and practice social distancing.  LCW’s previous guidance about not allowing employees and students returning from travel to Level 3 countries to come to work for a 14-day period of time applies equally to the above countries.   The CDC’s Level 3 Notices continue to also apply for travel to Iran, South Korea, and China.

D.       The CDC Has Determined that Other Travel Falls Within the Level 2 Risk Category

Previously, when we last reported on this issue, the CDC issued a Level 2 Travel Notice only regarding travel to Japan.  A Level 2 Notice recommends that travelers practice enhanced precautions, and that travelers returning from countries with Level 2 Notices monitor their health and limit interactions with others for 14 days after returning from travel.  Previously, we advised that schools consider, on a case by case basis, whether students or employees returning from a country with a Level 2 Notice could return to school while still having limited contact with others during this 14-day period.   Since we provided this advice, the CDC now states global travel to countries that do not have Level 3 Notices is still considered a Level 2 risk.  The CDC has declared that sustained community spread of COVID-19 has been reported globally, how or where some individuals became infected is not known, and virus transmission is ongoing. The CDC has stated there is evidence that COVID-19 is spreading in most regions and has been characterized as a pandemic by the World Health Organization.

The CDC recommends that older adults and people of any age with serious chronic medical conditions are at higher risk for severe disease, and that people in these groups discuss travel with a healthcare provider and consider postponing all nonessential travel.  The CDC states those who have traveled to any destination during the past 14 days, should monitor their health and practice social distancing.  The CDC defines social distancing as “staying out of crowded places, avoiding group gatherings, and maintaining distance (approximately 6 feet or 2 meters) from others when possible.”

Based on this updated guidance, schools should be asking families and employees about whether they have traveled internationally within the past 14 days or if they are planning to.   Schools will need to assess, on a case by case basis, whether they can accommodate the CDC’s social distancing recommendations for the 14-day period after employees and students return from international travel to Level 2 countries.   Schools should also coordinate with local health officials regarding the protocols that should be followed for students and employees who return from international travel.

E.        The CDC Issued an Advisory Concerning all Domestic Travel Within the United States

While the CDC does not generally issue advisories or restrictions for travel within the United States, due to the spread of COVID-19 within the United States, the CDC has issued new guidance regarding domestic travel.  The CDC states that crowded travel settings, like airports, may increase a person’s risk of exposure to COVID-19, and before traveling domestically, travelers should consider: (1) if COVID-19 is spreading where they are going; (2) whether during the trip they will be in close contact with others; (3) whether travelers or their travel companions are at higher risk of severe illness from COVID-19; (4) whether travelers have a plan in place for taking time off work or school in  the event of exposure to COVID-19; (5) whether travelers live with someone who is older or has a severe chronic health condition; and (6) whether COVID-19 is spreading where the travelers live.   In light of the CDC’s guidance, which acknowledges the increased risk of COVID-19 exposure for those traveling domestically, we recommend that schools consider cancelling or postponing trips that involve domestic travel.