SUNY Continuity of Operations Plan for a State Disaster Emergency Involving a Communicable Disease

Purpose

To ensure the continuation of services provided by the State of New York and the health and safety of the public sector workforce, each New York State agency and authority must prepare a plan for the continuation of operations in the event that the Governor declares a state disaster emergency involving a communicable disease.

Applicable agencies and authorities must post finalized plans by April 1, 2021 in (1) a clear and conspicuous location (e.g., bulletin boards or other similar location where employees normally view information posted by the employer), (2) in their employee handbook if they have one, and (3) on either their intranet or internet website.

Continuity of Operations Plan for a Disaster Emergency Involving a Communicable Disease

Individual(s) Responsible for Maintaining this Plan:
Megan Baldwin
Special Advisor to the Chancellor on Public Health Policy
Megan.Baldwin@SUNY.edu
518-801-2505

Date of Posting:
April 1, 2021

Statutory Elements of the Plan:

• A list and description of the types of positions considered essential in the event of a state-ordered reduction of in-person workforce.
  • "Essential" shall refer to a designation made by the employer that an employee is required to be physically present at a worksite to perform their job. Such designation may be changed at any time in the sole discretion of the employer.
• A description of protocols the employer will follow for non-essential employees to telecommute including, but not limited to, facilitating or requesting the procurement, distribution, downloading and installation of any needed technology, including software, data, and the transferring of office phone lines to work or personal cell phones as practicable or applicable to the workplace, and any devices.
• "Non-essential" shall refer to a designation made by the employer that an employee is not required to be physically present at a work site to perform his or her job. Such designation may be changed at any time in the sole discretion of the employer.
• A description of how the employer will, to the extent possible, stagger work shifts of essential employees in order to reduce overcrowding on public transportation systems and at worksites.
• A description of the protocol that the employer will implement in order to procure the appropriate personal protective equipment for essential employees, based upon the various tasks and needs of such employees, in a quantity sufficient to provide personal protective equipment to each essential employee during any given work shift. Such description shall also include a plan for storage of such equipment to prevent degradation and permit immediate access in the event of an emergency declaration.
• A description of the protocol in the event an employee is exposed to a known case of the communicable disease that is the subject of the state disaster emergency, exhibits symptoms of such disease, or tests positive for such disease in order to prevent the spread or contraction of such disease in the workplace. Such protocol shall also detail actions to be taken to immediately and thoroughly disinfect the work area of any employee known or suspected to be infected with the communicable disease as well as any common area surface and shared equipment such employee may have touched, and the employer policy on available leave in the event of the need of an employee to receive testing, treatment, isolation, or quarantine. Such protocol shall not involve any action that would violate any existing federal, state, or local law, including regarding sick leave or health information privacy.
• A protocol for documenting hours and work locations, including off-site visits, for essential employees. Such protocol shall be designed only to aid in tracking of the disease and to identify the population of exposed employees in order to facilitate the provision of any benefits which may be available to certain employees on that basis.
• A protocol for how the public employer will work with such employer's locality to identify sites for emergency housing for essential employees in order to further contain the spread of the communicable disease that is the subject of the declared emergency, to the extent applicable to the needs of the workplace. 

Any other public health requirements determined by the New York State Department of Health (DOH) that are designed to reduce transmission of infectious diseases, such as face coverings, contract tracing, diagnostic testing, social distancing, hand and respiratory hygiene, and cleaning and disinfection protocols.

A) Essential Personnel

What are the positions your agency or authority considers essential in the event of a state-ordered reduction of your in-person workforce?  Please provide a list and description of the types of positions.

Essential shall refer to a designation made that a public employee is required to be physically present at a worksite to perform his or her job. Such designation may be changed at any time in the sole discretion of the employer.

Below is a list and description of the types of positions in SUNY System Administration who may be deemed essential based in the above definition:

SUNY Campus Presidents are responsible for final determinations as to which functions or employees are essential based on how the crisis is developing or present on campus. In addition to campus leadership such as the Campus President, essential functions at the campus level also include functions required to support the well-being of individuals who remain on campus as well as the maintenance of SUNY properties and resources. Below is a list of positions/functions at the campus level that may be essential in responding to a disaster emergency involving a communicable disease:

B. Telecommuting

What are the protocols your agency or authority will follow for non-essential employees to telecommute including, but not limited to, facilitating or requesting the procurement, distribution, downloading and installation of any needed technology, including software, data, and the transferring of office phone lines to work or personal cell phones as practicable or applicable to the workplace, and any devices?  Please provide a description of these protocols as follows:

The Governor’s Office of Employee Relations (GOER) has the authority to establish a Statewide, uniform, telecommuting program which outlines how agencies/authorities manage telecommuting. In the event of a future state disaster emergency involving a communicable disease, SUNY will receive direction from GOER on the rules and guidelines applicable to telecommuting and will take the necessary steps in order to implement and operationalize any official telecommuting program, where applicable, for SUNY, including:

• Protocol for procurement, distribution, downloading and installation of needed technology:
• Protocol for phone coverage and transfer of office phone lines to work or personal cell phones:

There are a variety of technological tools available to support a remote workforce. Each campus may employ different tools, but they include online access from anywhere to Blackboard or other online learning system, Microsoft Office 365, One Drive, Word, Excel, PowerPoint, Teams, and SharePoint. In addition to these software tools, we may provide access to desktops and lab computers, and loaner laptops, Chromebooks, tablets, and other technological resources.

While campus and System Administration phone systems are different, they support ways to remotely access your calls and voicemail. Call forwarding is also available. Employees should check with the Help Desk to see what is available. Additionally, cell phone use is prevalent, and many employees choose to use their cell phones as their primary contact.

• SUNY will periodically assess its technology needs for telecommuting and work with the Office of Information Technology to ensure that appropriate information technology resources are available.
• Will you need to alter working hours/shifts/schedules of essential employees?
• Will you need to split shifts or change operations to different days of the week?
• How will you manage engagement between employees and any clients and/or visitors at the worksite, accounting for physical distancing requirements, as applicable?
• How will you promote physical/social distancing in this type of operation or work setting?
• What common situations that may not readily allow for 6 feet of distance between individuals exist at the worksite (including employees, clients and essential visitors)?

In the absence of a Statewide telecommuting program, SUNY will work within the confines of current labor management structures to determine the appropriateness of employee presence on campus, to include the possibility of assigning alternate work locations. Until a decision is made by the University about the nature and extent of the emergency, or a closure by the Governor, all employees should report to work as usual. Thereafter, management will determine and communicate which functions are essential and if any essential personnel will be excused from reporting to work and/or a physical work location.

C. Work Shifts/Schedules

How will your agency or authority, to the extent possible, stagger work shifts or adjust work hours of essential employees in order to reduce overcrowding on public transportation systems and at worksites? Consider the following in developing your work shift/schedule adjustments, if applicable:

• Will you need to alter working hours/shifts/schedules of essential employees?
• Will you need to split shifts or change operations to different days of the week?
• How will you manage engagement between employees and any clients and/or visitors at the worksite, accounting for physical distancing requirements, as applicable?
• How will you promote physical/social distancing in this type of operation or work setting?
• What common situations that may not readily allow for 6 feet of distance between individuals exist at the worksite (including employees, clients and essential visitors)?

SUNY will ensure that essential employees can continue to fulfill their work responsibilities within the confines of what is advisable by the WHO, CDC, OSHA and/or required by NYS or its DOH. In a future communicable disease event, current procedures and guidelines for workplace safety protocols will be adjusted to fit the specific threat and be distributed to all employees. Considerations will be made, within the confines of collective bargaining agreements and civil service laws, rules or regulations, to modify working hours, shifts, and schedules in such a way that social distancing and other workplace safety protocols can be enforced. We will ensure that appropriate physical and social distancing is followed for those physically present at work. These guidance documents include the following key elements:

• Employees required to physically report to the office may work with their supervisor on an individualized work schedule that will meet specific operating requirements and their personal needs. Subject to operating needs, an individualized work schedule can include:
• Permitting essential employees to flex their schedules around available childcare, working some or all of their hours on evening and/or weekend shifts when alternate care options are available, dependent on operational needs.
• Adjusting building access (hours and security) to support flex schedules.
• Office Social Distancing:
• During the current emergency, SUNY evaluated and adjusted its individual and community office space to comply with social distancing requirements. These measurements will be kept and adjusted as needed during the next contagious disease emergency, in accordance with the threat.
• Supervisors will monitor work schedules and limit occupancy in any enclosed space to no more than 50% and maintain a 6-foot distance between individuals, or in accordance with the guidelines for the next pandemic threat.
• Physical partitions or other barriers may be installed where recommended social distancing between staff is not possible.

D. Personal Protective Equipment

What is the protocol your agency or authority will implement in order to procure the appropriate personal protective equipment (PPE) for essential employees, based upon the various tasks and needs of such employees, in a quantity sufficient to provide personal protective equipment to each essential employee during any given work shift?  You should consider different job groupings or responsibilities (e.g., patient/direct care, public-facing positions) when describing the protocol. Also, consider the following in developing your protocol:

• What is your plan for storage of such PPE to prevent degradation and permit immediate access in the event of an emergency declaration?
• What will be your protocol for cleaning and/or disposal of PPE, to the extent applicable?
• How will you train employees on how to put on, take off, clean and disinfect (as applicable) and discard PPE?
• What is your plan for posting signage to remind employees of appropriate use of PPE?

SUNY follows Infection Control Procedures in accordance with the Center for Disease Control, Occupational Safety and Health Administration, and the New York State Department of Health in the development of all internal protocols and guidance relative to responding to communicable disease.

During a response to a communicable disease outbreak, procuring, distributing and inventory control will be centralized and prioritized.  The Office of Environmental Health and Safety will coordinate these activities and supplies will be procured via OGS or from well-established New York State suppliers.

It is the responsibility of each campus to ensure that there are adequate medical (general medical supplies, medications and PPE) and nonmedical (for implementation of CDC and OSHA recommended infection control and biosafety measures; cleaning and disinfecting) supplies to cover a public health emergency. SUNY's PPE supply is stored at each campus location pursuant to PPE storage requirements and is overseen and distributed by the Office of Environmental Health and Safety. Each campus will ensure that employees are provided training on the proper donning, doffing, cleaning (as appropriate) and disposal of PPE.

E. Exposure Protocol

What is the protocol in the event an employee is exposed to a known case of the communicable disease that is the subject of the state disaster emergency, exhibits symptoms of such disease, or tests positive for such disease in order to prevent the spread or contraction of such disease in the workplace?  Current requirements under the COVID-19 disaster emergency, as follows, should be taken into account in the description of your protocol:

• Implement mandatory remote or in-person daily health screening for COVID-19 contact or symptoms (e.g., questionnaire, temperature check) for in-person employees at or near the beginning of each workday.
• Coordinate screening to prevent employees from intermingling in close contact with each other prior to completion of the screening.
• Ensure agency/authority is following all screening, testing, and tracing procedures as outlined in the applicable DOH guidance, including instructions to employees on when to return home and when to return to work.
• Ensure screening staff are trained supervisory-level employees or health care professionals, wearing appropriate personal protective equipment including at least a face covering and gloves, if the screening involves contact.
• Maintain a record of all staff who are screened, as well as if screening was passed or if the staff member was instructed to return home, provided no other health information is recorded or maintained. Record must be reviewed and secured on a daily basis.
• Designate a worksite-level safety monitor whose responsibilities include continuous compliance with all aspects of the site safety plan.
• Where practicable, maintain a log of every person, including employees and visitors, who may have close contact with other individuals at the worksite or area, excluding deliveries that are performed with appropriate PPE or through contactless means.

SUNY will utilize engineering controls, safe work practices and PPE in order to minimize exposure in a future state disaster emergency caused by a communicable disease which will be dependent on the communicable disease that causes such disaster emergency. 

SUNY will provide periodic updates, as information becomes available, on the communicable disease and its transmission as part of its exposure protocols in order to assist with reducing transmission.

SUNY, together with NYS, has created a series of procedures to ensure that all employees physically reporting to work are screened for infectious disease and that the results of the screenings are collected and instantly reviewed. These protocols follow all screening, testing, and tracing procedures as outlined in the applicable NYS DOH guidance, including instructions to employees on when to return home and when to return to work. Protocols are updated as circumstances change.

SUNY System Administration has worked with the SUNY hospital network to develop tests in the current pandemic and requires weekly testing of all employees physically present at SUNY campuses. Testing protocols can be modified to support other testing needs.

Employees who are physically reporting to work must complete the Daily Office COVID Screening within the first hour of physically reporting to the workplace. This includes employee's coming into the building only for a brief period.

Procedures have been developed to comply with directives from the Director of State Operations and Infrastructure memorandum, entitled, “Employee Testing and Evaluation Protocols for COVID-19,” which includes cleaning and disinfecting protocols, as well as notification to health officials as required. SUNY also directs the daily thorough disinfection of any work area of any in person employee as well as any common area surface and shared equipment such employee may have contaminated including:

• Building and elevator lobbies.
• Restrooms & drinking fountains.
• Hallway light switches, turnstiles, and waste receptacles.
• Building entrances, stairwell doors and handrails.

While the amount and types of leave available to an employee will be dependent on the particular communicable disease emergency that has been declared and any provisions of law that provide for leave under such circumstances, during a communicable disease emergency an employee's leave options include GOER quarantine leave, other applicable State policy leave, leave provided under a Federal Act and an employee's own leave accruals. Collective Bargaining Agreements may also be applicable. Policy on available leaves will be established by the Department of Civil Service and/or GOER who shall provide guidance to the agencies/authorities on how to instruct employees about available leaves.

F. Protocol for Documenting Work Hours/Locations

How will your agency or authority document hours and work locations, including off-site visits, for essential employees? Your protocol shall be designed only to aid in tracking of the disease and to identify the population of exposed employees in order to facilitate the provision of any benefits which may be available to certain employees on that basis.  You should also consider the following questions in describing your protocol:

• How will these records be maintained?
• Who is responsible for maintaining these records?
• Who will be in charge of accessing these records for the purposes of disease tracking and identifying potential exposures?
• If these records are in paper form, what are your protocols for preserving these records?

Each campus is responsible for tracking the population of exposed employees in order to facilitate the provision of any benefits which may be available to certain employees on that basis. Employees entering SUNY worksites must undergo a health screening which is recorded as described in Section E (above). Logs from that application are saved daily and are accessible by key personnel including the Chief Operating Officer and Human Resources Office who will use the information for the purposes of disease tracking, identifying potential exposures, and contact tracing.

G. Protocol for Identifying Emergency Housing for Essential Employees

How will you work with local officials to identify sites for emergency housing for essential employees in order to further contain the spread of the communicable disease that is the subject of the declared emergency, to the extent applicable to the needs of the workplace? 

To the extent needed, your agency’s/authority’s Director for Administration (DFA) (or in the case of facility operations the local equivalent) will be the point of contact for the identification of emergency housing for essential employees.  The DFA or local equivalent will be responsible for contacting county and local elected officials, owners/operators of local hotels and similar establishments, and local college and university officials (both public and private) to develop information about the local availability of emergency housing for essential employees. Emergency housing opportunities, once developed, will be communicated to employees who may be in need of such housing.

Each campus will be responsible for contacting county officials, hotels and college and university officials to develop information about the availability of emergency housing for essential employees. Emergency housing opportunities, once developed, will be communicated to employees who may need such housing.

H. Other Requirements Determined by the NYS DOH

• Current DOH guidelines for COVID-19 are as follows and will be modified depending on the particular emergency declared.
• Ensure a distance of at least 6 feet is maintained among employees at all times, unless safety of the core activity requires a shorter distance (e.g., moving and lifting equipment). Any time an employee must come within 6 feet of another person, the employee and person should wear acceptable face coverings.
• When distancing is not feasible between workstations or areas, provide and require the use of face coverings or erect physical barriers, such as plastic shielding walls, in lieu of face coverings in areas where they would not affect air flow, heating, cooling, or ventilation.
• Tightly confined spaces should be occupied by only one individual at a time, unless all occupants are wearing face coverings. If occupied by more than one person, occupancy will be kept under 50% of maximum capacity.
• Social distancing markers should be posted around the workplace using tape or signs that indicate 6 feet of spacing in commonly used areas and any areas in which lines are commonly formed or people may congregate (e.g., clock in/out stations, health screening stations, break rooms, water coolers, etc.). Further, bi-directional foot traffic should be reduced by using tape or signs with arrows in narrow aisles, hallways or spaces.
• Post signs, consistent with the DOH COVID-19 signage, to remind employees about social distancing, hand hygiene, PPE, and cleaning/disinfecting guidelines.
• Limit employee travel for work to only essential travel.
• Hygiene and sanitation requirements from the Centers for Disease Control and Prevention (CDC) and DOH must be followed, and cleaning/disinfecting logs that that include the date, time, and scope of cleaning must be maintained.
• Hand hygiene stations, including handwashing with soap, water, and disposable paper towels, as well as NYS Clean hand sanitizer or a hand sanitizer containing 60% or more alcohol for areas where handwashing facilities may not be available or practical, must be provided and maintained for personnel.
• Appropriate cleaning/disinfection supplies for shared and frequently contaminated surfaces must be provided, and employees must use these supplies before and after use of these surfaces, followed by hand hygiene.
• Regular cleaning and disinfection of the office location must be undertaken. More frequent cleaning and disinfection must be undertaken for high risk areas used by many individuals and for frequently contaminated surfaces, at least after each shift, daily, or more frequently as needed, and align with DOH’s “Interim Guidance for Cleaning and Disinfection of Public and Private Facilities for COVID-19”.
• Exposed areas must be cleaned and disinfected in the event of an employee testing positive for COVID-19. Such cleaning should include, at a minimum, all heavy transit areas and high-touch surfaces (e.g., vending machines, handrails, bathrooms, doorknobs, etc.).
• CDC guidelines on “Cleaning and Disinfecting Your Facility” should be complied with if someone in your facility is suspected or confirmed to have COVID-19.
• Agencies/authorities must have internally identified key points of contact including but not limited to site safety monitors, individuals responsible for monitoring compliance with this plan and central points of contact who will coordinate efforts to notify appropriate health authorities of positive cases and assist with required contact tracing.

SUNY will also comply with all executive orders and emergency regulations related to the state disaster emergency.