1. Reason for this Regulation

1.1 The COVID-19 pandemic has resulted in critical shortages of personnel in the Pitt County Health Department to sufficiently identify and collect information on individuals who have had close contact with others who have contracted COVID-19, per the Centers for Disease Control and/or North Carolina Department of Health and Human Services guidelines (such process is referred to herein as “Contact Tracing”).

2. Where and to whom does this Regulation apply?

2.1 This regulation applies to all ECU employees and students:

2.1.1 Onsite at a University location, including, but not limited to, ECU’s Greenville campus, the Coastal Studies Institute, and the School of Dental Medicine’s Service Learning Centers that are located throughout North Carolina.

3. Administration of Contact Tracing Program

3.1 In Section 5.1 below, Chancellor has designated a Designee who is responsible for overseeing the University’s Contact Tracing efforts. The Designee may appoint a COVID-19 Contact Tracing Coordinator (“Coordinator”) to:

3.1.1 Coordinate individuals performing Contact Tracing on the University’s behalf (“Contact Tracing Program”).

3.1.2 Schedule individuals performing Contact Tracing on the University’s behalf

3.1.3 Direct and manage individuals performing Contact Tracing on the University’s behalf.

3.2 The individuals working within the Contact Tracing Program may be University employees, students working for course credit or as part of a curriculum, or volunteers.

3.2.1 All individuals working with the Contact Tracing Program, whether as an employee, student, or volunteer, shall receive formal training in HIPAA and Contact Tracing that is consistent with CDC guidelines.

3.2.2 Any such training, whether provided as part of a university course for credit or made available by the Pitt County Health Department, or otherwise, must be approved by Designee, and the Designee must keep documentation of the training in the records of the Contact Tracing Program.

3.2.3 All participants in the Contact Tracing Program must sign an agreement indicating their willingness to maintain confidentiality and to perform their duties diligently and as directed by the Coordinator and/or Designee.

3.3 The Designee and Coordinator must maintain records of the dates, times, assignments, and responsibilities of each individual working with the Contact Tracing Program so that:

3.3.1 Audits may be performed

3.3.2 Quality is assured

3.3.3 Any data breaches can be investigated

3.3.4 Individuals can be held accountable for their work (whether through discipline as an employee, evaluation as a student, dismissal from the Contact Tracing Program, and/or any other appropriate accountability measure). See Section 8 below.

3.4 The Designee shall be responsible for the development, adoption, and implementation of Standard Operation Procedures and protocols implementing all aspects of the Contact Tracing Program.

4. Duties of Contact Tracing Program

4.1 The Contact Tracing Program will be responsible for:

4.1.1 Contact Tracing students who are either diagnosed in University’s Student Health Services or who self-report to the University.

4.1.2 Contact Tracing employees who are either diagnosed in University’s Office of Prospective Health or who self-report to the University.

4.2 To the extent feasible, University will cross-reference data provided by Pitt County with University’s database of employees and students and initiate Contact Tracing with those individual employees or students to the extent the individuals have not already self-reported or been diagnosed in Student Health or Prospective Health.

4.3 The Contact Tracing Program will endeavor to identify close contacts of students and employees with confirmed COVID-19 in accordance with protocols approved by the Pitt County Health Department.

4.4 If the confirmed COVID-19 contacts are University students and/or employees, the Contact Tracing Program will immediately provide the individuals with relevant guidelines, including:

4.4.1 Recommended quarantine and isolation guidance based on guidelines from the CDC and Pitt County Health Department (Contact Tracing Program will monitor students throughout their isolation and quarantine)

4.4.2 Contacts will be educated on symptom monitoring, when to seek medical care and testing guidelines

4.5 The Contact Tracing Program is not responsible for conducting Contact Tracing for individuals who are not University students or employees.

4.5.1 If individuals are identified through Contact Tracing who are not University students or employees, the Designee shall share such information on these individuals with the County, in a mutually agreed upon method, as promptly as possible.

4.6 The Designee will share and provide Pitt County with requested information on students and employees testing positive for COVID-19, as well as individuals identified through Contact Tracing.

4.7 The Designee will participate as needed in communication with the Pitt County Health Department in order to coordinate contact tracing efforts and to make certain that the necessary information is being relayed to the Pitt County Health Department regarding persons who have been found to be exposed or potentially exposed to persons with COVID-19.

4.7.1 Designee will participate in a minimum of one teleconference or in-person meeting every week with the Pitt County Health Department’s central point of contact

4.7.2 This regular communication will address, among other things, outbreaks in dorms, sports teams, and in-person learning environments.

4.7.3 Designee will be responsible for ensuring all known students and employees who test positive for COVID-19 are reported to the Pitt County Health Department as required by N.C.G.S. Section 130A-136. This may be accomplished through coordination with the Director of the Office of Prospective Health or with the labs conducting the tests.

4.7.4 All communications, both with campus community members and with those outside of the campus community, shall comply with applicable state and federal laws, including HIPAA, FERPA, and the confidentiality provisions contained in N.C.G.S. Section 130A-143.

4.7.5 All members of the Contact Tracing program will be trained in the applicable confidentiality regulations so that their communications with ECU students and employees are made in compliance with state and federal privacy and confidentiality laws.

4.7.6 Information regarding positive test results of ECU students and employees will be conveyed in a compliant manner via the website https://covid-19.ecu.edu/.

4.8 All participants of the Contact Tracing Program will notify Designee if they know or have a reasonable suspicion of confirmed COVID-19 cases in a University student or employee, violating any County-issued control measure.

4.8.1 Designee shall investigate such situation as appropriate and notify Pitt County Health Department’s designated central point of contact of any such violation of a County-issued control measure (including but not limited to quarantine or isolation orders).

4.9 Designee is responsible for complying with the control measures issued by the Pitt County Health Department that provides that the University shall share the minimum necessary information about suspected or confirmed COVID-19 positive cases or those under isolation and quarantine orders with those University departments and employees with a need to know in order to:

4.9.1 Clean or disinfect facilities

4.9.2 Provide academic support to students and employees

4.9.3 Provide residential support to students

4.9.4 Provide healthcare support to students and employees

4.9.5 Provide other appropriate support to students and employees

4.9.6 Make appropriate notifications to the University community regarding clusters or concentrations of outbreaks.

4.10 Other than as provided in this Regulation, Designee will not share and will not allow the sharing of any potential protected health information on suspected or confirmed COVID-positive cases (e.g., with professors or students in a class), except:

4.10.1 as necessary through the University’s formal contact tracing efforts following County-approved methods;

4.10.2 with the consent of the individual; or

4.10.3 to the County (e.g., when University’s designated central point of contact becomes aware of noncompliance with isolation or quarantine orders)

4.11 When the Contact Tracing Program does not have the capacity to investigate a majority of its new COVID-19 cases, case investigation and contact tracing may not be the most effective approach.

4.11.1 Designee at all times will keep the ECU COVID-19 Coordination Committee informed with the Contact Tracing Program’s capacity to investigate.

4.11.2 If Designee informs the COVID-19 Coordination Committee that the Contact Tracing Program no longer has the capacity to investigate the majority of its COVID-19 cases, the COVID-19 Coordination Committee will consider suspending or scaling down contact tracing activities and reimplementing strict mitigation measures (such as stay-at-home orders, building closures, and school closures) until transmission begins to decline.

5. Designated Contact Tracing Point of Contact

5.1 By adoption of this Interim Regulation, the Chancellor designates the Director of Student Health (“Contact Tracing Designee” or “Designee”) as the central point of contact responsible for facilitating communication with the Pitt County Health Department and leading the University’s Contact Tracing efforts. The Chancellor may change this Designee at any time by written communication to the Pitt County Health Department.

6. Relation to Governmental Policies

6.1 All students, faculty, staff, contractors, and visitors are expected to know and comply with all recommendations and requirements of the state and municipal authorities in locations where they study, live, or work (e.g., directives of the State of North Carolina, Pitt County, and the City of Greenville and other local municipalities). 

7. Duration of Regulation

7.1 This Regulation is effective immediately and will remain in effect indefinitely until withdrawn or modified by the Chancellor as guided by appropriate public health information and officials. 

8. Compliance and Enforcement

8.1 Compliance with this Regulation is mandatory. For students, compliance with this Regulation is a condition of continued enrollment. Failure to comply with this policy may result in administrative action, including, but not limited to, disciplinary action under the Student Code of Conduct, restriction on access to, or use of, University facilities, removal from University housing, disenrollment from one or more in-person courses, transition to remote-only instruction and/or other interventions necessary to effect compliance and protect the well-being of the campus community. For employees, compliance with this Regulation is a condition of continued employment. In the case of willful failure to comply with the provisions of this policy and/or repeated violations, the University may pursue additional disciplinary actions in accordance with applicable University policies.