Back to campus: higher education concerns, risks and opportunities

Higher education leaders have spent the last six-plus months determining how to bring students, faculty and staff back to campus in a safe and responsible way. The challenge has been significant and, as you know, the situation has been changing week to week and, often, day to day.

Baker Tilly recently presented a webinar to discuss some of the key concerns and risks facing colleges and universities as it pertains to the return to campus. Additionally, we discussed ways in which these current issues can turn into opportunities – both in the near future and in the long run – as institutions begin to reconstruct and adapt to a COVID-19 world.

Impacts to campus workforce and budget

Thinking back to March, the majority of campuses closed quickly. Colleges and universities had to abruptly and unexpectedly examine every aspect of how they work, including who needed to be on campus, who could work remotely, what technology was required and how human resources (HR) processes and budgets needed to change. As institutions handle the workforce impacts of COVID-19, you may need to:

• Change schedules: Utilize remote work and leverage flexible schedules for faculty and staff to the extent possible
• Maintain FFCRA compliance: Remember obligations under the Families First Coronavirus Response Act (FFCRA)
• Review HR-related policies: Ensure policies are current and compliant; in particular, pay attention to Family and Medical Leave Act (FMLA), paid time off (PTO)/vacation and other types of leave
• Beware of legal minefields: Focus on issues related to safety, discrimination, wage and hour, Worker Adjustment and Retraining Notification (WARN) Act and Employee Retirement Income Security Act (ERISA)/Consolidated Omnibus Budget Reconciliation Act (COBRA) claims
• Keep things afloat: Actively manage the changing workforce to ensure operations can continue as the pandemic evolves

It is important to keep in mind that being a trusted employer is critical, that it is pivotal to communicate constantly and that the way you handle COVID-19 and the return to campus will have a lasting impact on your faculty, staff and students.

Safety concerns for faculty and staff returning to campus

Whether your institution is currently conducting classes virtually, in-person or via a hybrid model, there are several safety precautions to take to ensure the highest level of protection for your faculty and staff. Some best practices pertaining to employee safety include:

• Adhere to federal, state and local workplace guidelines: Understand and maintain compliance with regulations on reopening, including building capacity, social distancing and mask requirements
• Follow testing guidelines: Establish and communicate testing and screening guidelines in accordance with the Centers for Disease Control and Prevention (CDC), Occupational Safety and Health Administration (OSHA) and state and local guidelines
• Establish common area expectations: Prepare and post safety signage and create “common area” rules identifying what activities must be limited or eliminated
• Determine cleaning procedures: Establish enhanced cleaning protocols in accordance with CDC and other relevant guidance
• Address faculty and staff requests: Be prepared for faculty and staff accommodation requests and know what your obligations are under the Americans with Disabilities Act (ADA)

Remember that there is no playbook for a situation of this nature. Whatever your institution decides after considering all requirements and guidelines, make sure to communicate clearly and openly with your faculty, staff and students.

Campus testing and monitoring considerations

While safety is always a priority, colleges and universities are not in the business of providing healthcare. However, now more than ever, the health of students must be moved to the top of your priority list. COVID-19 testing is a widely used approach to ensure the health of students, as studies show a 60% reduction in infectiousness with weekly testing and a 40% reduction with bi-weekly testing. Your institution may need to examine the following testing considerations if you have not already:

Symptomatic testing

• How will students be prompted to get tested (e.g., through a symptom tracking app)?
• Where will students be directed to for testing and healthcare advice?
• Will testing be conducted in-house or outsourced?
• What format of testing will be used?

Surveillance testing

• Will surveillance testing be performed?
• What population will be tested?
• How frequently?
• Will testing be conducted in-house or outsourced?
• What format of testing will be used?
• How will surveillance metrics be monitored?
• At what thresholds will leadership consider changes in operations?

End of semester testing

• Will students be tested prior to leaving campus and returning home?
• How will testing be tracked and monitored?

Return to campus testing in the spring

• Will all students be tested prior to returning to campus?
• Should testing be conducted in their home communities or on campus?
• What protocols should international students or those from travel-restricted states follow?

CARES Act compliance considerations

The Coronavirus Aid, Relief, and Economic Security Act (CARES) Act and the Higher Education Emergency Relief Fund (HEERF) have forced institutions to consider many questions, including:

• How is your institution monitoring HEERF compliance (e.g., performing audits or reviews during or after the awarding process)?
• Are the methodology and assumptions used to determine eligible expenses and amounts
  to be awarded to students formally documented and up-to-date?
• How is your institution tracking the amounts awarded in student emergency financial aid grants, as well as the expenses reimbursed with the institutional component?
• Has your institution fulfilled all reporting obligations timely, at the required frequency and with all necessary elements included?

Efficiency and controls impacts of remote work environment

Moving to a remote platform, as many universities have, has changed the way that you do business, what your operations look like and the risks that you face on a daily basis. There are several areas in which the switch to a remote environment has proved particularly challenging.

• Time charging and productivity – Overseeing the time and productivity of remote employees is a complex area. Institutions are doing your best to identify pitfalls and assist employees who are struggling, and to ensure timekeeping practices are flexible but accurate to meet employee needs while ensuring that any commitments (e.g., extramural funding requirements, collective bargaining agreement stipulations) are met.
• Procurement – If you have switched to a system where goods, such as electronics or office supplies, are now being sent to employees’ home rather than to the workplace, you may face concerns surrounding volume of purchases, appropriateness of charging and logistics of receipts and returns. Some institutions are performing analytics to identify potential “red flags” such as spikes in purchasing and unexpected merchant category codes on procurement cards; these flags can then be investigated to identify specific challenges and/or broadly needed updates to procurement policies and procedures.
• Automation of processes – Some of what you used to do in person can no longer happen remotely (e.g., physically signing documents). In many cases, institutions have pivoted to more automated practices that actually increase efficiency; however due to swiftness of the change, there are lingering operational and fraud risks in these processes. Some institutions are using this time to perform a detailed fraud risk assessment to identify risks and ensure appropriate mitigating controls are in place.
• Cybersecurity and privacy concerns – This may be the time to look critically at your internal controls and the associated risks. Ask yourself if the processes you have in place are mitigating the risks to the degree required by the current environment.

The COVID-19 pandemic presents numerous considerations and risks for colleges and universities as the situation evolves. It’s crucial for higher education leaders to continuously monitor and communicate campus activities and adhere to guidelines, while remaining flexible and committed to the institution’s mission.