August 5, 2020

Dear faculty and staff,

The Reed COVID-19 Risk Assessment Working Group has received the following question related to COVID-19 disclosure and FERPA from a number of faculty and we are sharing the answer with all of you as an FYI.

Q. What will faculty/instructors know regarding COVID status of students in their class? While FERPA protects personal identifying information of students, it appears that COVID-19 can be considered under the provisions of an emergency and threat to other students. Therefore, the Reed faculty would like to know how Reed is interpreting the DOE statement.

A. The correct link to DOE guidance is here. The department's guidance allows the school to disclose personally identifiable information when ". . . a disclosure of the student's name is absolutely necessary to protect the health or safety of students or other individuals or whether a general notice is sufficient, taking into account the totality of the circumstances, including the needs of such students or other individuals to have such information in order to take appropriate protective action(s) and the risks presented to the health or safety of such students or other individuals." Since Reed will be operating with mandatory mask wearing protocols and with restrictions on close association in gatherings and classrooms, Reed would notify, based on contact tracing by Multnomah County and Reed, close contacts of someone who tested positive. This would generally not include the entire residence hall or an entire classroom and would generally not require that the infected student be identified by name.

More information regarding case notification is listed here.

If you have further questions, you can reply to this email address or contact the Dean of the Faculty's office.

Thank you,
Mandy Heaton
Public Affairs
Responding on behalf of the Reed COVID-19 Risk Assessment Working Group