On October 8, 2020, Toronto Public Health (“TPH”) released a revised version of its COVID-19 Guidance for Child Care Settings (the “Revised Guidelines”), setting out the most up-to-date guidelines for child care centres in the Toronto region with respect to COVID-19. The key changes under the Revised Guidelines relate to how child care centres must screen staff and children and how long individuals must be excluded from child care settings for reasons related to COVID-19, among other changes.
Revised Screening Guidelines
Under the Revised Guidelines, the COVID-19 screening tools that should be used to screen individuals prior to entry into the child care settings are as follows:
- The Ministry of Health COVID-19 Screening Tool for Children in School and Child Care should be used for children; and
- The Ministry of Health COVID-19 Screening Tool for Workplaces (Businesses and Organizations) should be used for staff/early education students and other adult visitors.
These screening tools replace the three questions set out in the previous version of the guidelines which applied to staff, students, adults and children.
Although the screening tool for children asks about most of the same COVID-19 symptoms as the questions under the previous guidelines (excluding abdominal pain and pink eye), this screening tool only asks about whether any of the questions are true for the child, rather than the child and the parent completing the screening. The screening tools also makes it even more clear that any symptoms related to other known causes or conditions need not be reported.
Revised Exclusion Guidelines
The Revised Guidelines provide new guidance on how long individuals need to be excluded from child care settings where they have COVID-19 related symptoms, have tested positive for COVID-19, or have been exposed to someone with COVID-19.
In particular:
- staff/students and children with a confirmed case of COVID-19 must be excluded from the centre and self isolate for at least 10 days from the onset of symptoms, and may only return to the child care setting once they do not have a fever and their symptoms have been improving for at least 24 hours;
- staff/students and children who have been exposed to a confirmed case of COVID-19 must still be excluded from the child care setting for at least 14 days, even if they test negative for COVID-19; and
- symptomatic children who have not been exposed to a confirmed case of COVID-19 and who test negative can return 24 hours after their symptoms begin to improve, they are well enough to participate in programming, and they pass the screening.
The Revised Guidelines have also clarified how long symptomatic children who are not tested for COVID-19 (and that do not have an alternate diagnosis) must be excluded from child care settings, at least in certain circumstances. Such children must be excluded from the centre if they have:
- one or more of the following symptoms: fever, cough, difficulty breathing or loss of taste/smell;
- one or more of the following symptoms that does not improve in 24 hours: sore throat, stuffy/runny nose, headache, nausea/vomiting/diarrhea, muscle ache/fatigue; or
- two or more of the following symptoms: sore throat, stuffy/runny nose, headache, nausea, vomiting, diarrhea, muscle ache/fatigue.
Children who meet any of those criteria must be excluded for at least 10 days. They then may only return if their symptoms have been improving for at least 24 hours and they are well enough to participate in programming.
Other Changes Under the Revised Guidelines
Other notable changes under the Revised Guidelines include:
- the guidelines no longer stipulate that screening stations for in-person screenings need to be outside, and only require that they be near the main entrance of the centre;
- mouthed toys can now be taken out of circulation after children have finished using them, to be cleaned and disinfected prior to being used by a different child, rather than being cleaned and disinfected immediately after use;
- the guidelines provide that the exceptions for when staff don’t need to wear a mask and eye protection may include when staff are performing duties in which they are separated from their cohort and other staff/students; and
- obtaining medical notes for excluded children to return to child care centres is not recommended or required by TPH.
Takeaways
With the second wave of the COVID-19 pandemic in full swing, child care centres in the Toronto region should ensure that they promptly update their COVID-19 screening practices in accordance with TPH’s Revised Guidelines. In particular, centres should begin using the applicable screening tools for children and for staff/students and adult visitors as soon as possible. With the recent rise in the daily number of new cases of COVID-19 in Ontario, it is more important than ever for child care centres to be able to show that they are taking all reasonable precautions to ensure the health and safety of everyone at their centres, which includes complying with the Revised Guidelines.
For the same reasons, child care centres in the Toronto region should also revise their policy regarding the exclusion of individuals from the centre for reasons related to COVID-19. Not only will doing so help meet centres’ legal obligations, it will also allow them to craft policies that provide greater clarity to staff and parents on how long individuals must be excluded from the centre in various circumstances, particularly where a symptomatic child is not tested for COVID-19. As our understanding of COVID-19 and the corresponding requirements continue to evolve, the value of ensuring that everyone is on the same page cannot be understated.
Further, as winter approaches, child care centres and their staff will also be glad to hear that TPH is no longer requiring that in-person screenings take place outdoors. Moreover, child care centres’ ability to allow employees to not wear PPE indoors where they are separated from their cohort and other staff may provide a small morale boost for staff that perform some of their duties in such circumstances.
We will continue monitoring the changing COVID-19 related requirements for child care centres, to keep you In the Know.
This blog is provided as an information service and summary of workplace legal issues.
This information is not intended as legal advice.