To: Directors of the Rochester School Board

From: Kent Pekel, Ed.D., Interim Superintendent

Date: March 1, 2022

Subject: Proposed Shift from Districtwide to Building-by-Building Mask Requirement

I am writing to outline a change that I believe our school system should make in the requirements we
have in place regarding the use of face coverings to mitigate the spread of the Covid-19 virus in our
schools and other facilities. Given the steep declines in the number of cases of Covid that are
occurring in our schools and our community, I recommend that we shift from requiring all students,
staff, and visitors to wear face coverings in RPS schools and other facilities at all times to strongly
recommending but not requiring face coverings unless 5% or more of the students and/or staff who
attend or work at an RPS school or other facility test positive for Covid-19. At schools that do not
meet the 5% threshold, students would also be encouraged but not required to wear masks during
extracurricular activities and while riding on school buses and other forms of transportation sponsored
by Rochester Public Schools. Such a shift in RPS’s approach to masking on school transportation
was made possible on February 25, 2022, when the U.S. Centers for Disease Control (CDC) revised
its guidance and discontinued its previous requirement that people wear masks on buses and vans
operated by public and private school systems.

The 5% threshold at which masks would be required in RPS schools and other facilities would be met
when 5% of all students and staff in a facility test positive for Covid during a weekly Covid reporting
period. Covid reporting periods in Rochester Public Schools begin at 12:00 AM each Monday and
conclude at 11:59 PM each Sunday. If a school has met the 5% threshold before 5 PM on Friday at
the end of the Covid reporting period, parents and students will be informed at that time that all
students and staff at the school will be required to wear masks for two weeks. If the school has not
yet met the 5% threshold by 5 PM on Friday but is nearing that threshold, parents and students will
be informed by 5 PM Friday that students may be required to wear masks for two weeks starting the
following Monday and that they will be notified if their school has passed the threshold by 6 AM on
Monday.

When the 5% threshold is met at a school or another RPS facility, all of the students and staff who
attend and/or work at the facility would be required to wear face coverings for two full weeks following
the Covid reporting period during which 5% or more of the students and staff tested positive. The
requirement to wear masks at the school or facility would be extended for an additional two weeks if
5% or more of the students and staff at the facility test positive for Covid during the second week of
mandatory masking.

If a school meets the 5% threshold and students and staff are required to wear masks for two weeks,
all spectators at and student participants in extracurricular activities would also be required to wear
masks for two weeks unless students are actively involved in competition, practice, or another activity
as stipulated in current Minnesota State High School League guidance. Similarly, masks would be
required for two weeks on school buses and other forms of transportation operated by Rochester
615 7th St. SW, Rochester, MN 55902-2052 | 507.328.4256
Public Schools (including transportation to and from extracurricular activities) if more than 5% of
students and staff in a school test positive for Covid. If a transportation route serves students from
another school(s) where students are not required to wear face coverings, students from the other school(s)
will also be required to wear face coverings for two weeks.

At present, no schools or other facilities within Rochester Public Schools meet the 5% threshold at
which masks would be required.

Where Masks Would Still Be Mandated

Even if the School Board approves the shift in mask requirements for most RPS schools and
programs outlined above, I recommend that we continue to require face coverings in the following
environments and conditions for the foreseeable future:

1. Students in our early childhood programs who are younger than five years of age

• Note: I recommend that we continue to require masks in these programs because the
children who attend them are currently too young to be eligible for vaccination. I
recommend we discontinue the masking requirement for our early childhood students if and
when vaccinations are approved for students younger than five years of age or if the
transmission of the Covid virus in Olmsted County reaches the medium level. In the
meantime, students in our early childhood programs will be able to participate in our
district’s Test to Stay program.

2. Staff who tested positive for Covid and who have completed five-day isolation period followed
by a negative test who would be required to mask in RPS facilities for days 6-10 following their
initial positive Covid test

3. Staff in our health services offices who provide direct services to students

4. Students who are demonstrating symptoms of Covid or who are being sent home for other
health-related reasons and are waiting to return home

It is important to note that if we adopt the revised approach to face coverings that I recommend in this
memo, all of the other elements of Rochester Public Schools’ Safe and Open Schools Plan and
strategy will remain in place, including but not limited to the following initiatives:

A. We will evaluate the transition to distance learning at the classroom, grade levels, and entire
schools if our previously established thresholds for transitioning to distance learning are met.
At the classroom level, that threshold is met when 15% of students and staff have symptoms of
Covid-19 or test positive for Covid-19. At the grade level, the threshold is met if 50% of staff
and students test positive or are symptomatic. At the school level, the threshold is met if 15%
of staff are absent for any reason (including but not limited to testing positive for COVID), or
25% of students are absent for any reason, or 10% of all students in the building have tested
positive for COVID.

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 B. We will require students who test positive for COVID to isolate for 10 days from the date of
onset of symptoms or from the date of the positive test if asymptomatic. This 10-day isolation
period is longer than the 5-day period that has been authorized by the U.S. Centers for
Disease Control (CDC) because the CDC recommends that the five day isolation period be
followed by careful wearing of a face covering for days 6-10 following a positive Covid test.
Because, if this recommendation is adopted, RPS would no longer have a universal mask
requirement in place (and also because many students struggle to fully cover their noses and
mouths with a mask even when a requirement is in place), we will continue to require the
longer period of isolation.

C. We will continue to ask students and staff to socially distance to the greatest extent possible.

D. We will make high-quality KN95 masks available to staff and secondary students who want to
wear them as long as supplies are available. Because the FDA does not recommend that
younger children wear KN95 masks due to their size and density, we will make other high-
quality masks available to our younger students as well.

E. We will continue to strongly encourage parents, guardians, and students to get vaccinated and
will partner with medical providers and public health agencies to facilitate vaccinations.

F. We will continually remind both students and staff that wearing masks is strongly
recommended even though it is not required, and we will take steps to ensure that RPS
students who choose to wear a mask feel supported and are not bullied, as is outlined in this
article from Boston Children’s Hospital: https://answers.childrenshospital.org/mask-bullying-
school/. We will ask school principals to proactively share that message with students and
parents through conversations in class and through school communications channels and we
will do the same through outreach from the school district level. We will note that individuals
who engage in disrespectful, harassing, or bullying behavior may be subject to disciplinary
action as outlined in the RPS Student Handbook.

While the shift in our approach to face coverings outlined in this memo is my recommendation, I
developed it through collaboration with our core Covid team and discussed it with principals, school
health office staff, central office administrators, and the President of the Rochester Education
Association. I also discussed it with our external public health and medical advisors at Olmsted
County Public Health and the Mayo Clinic. While none of those key stakeholders should be seen as
endorsers of this proposal, it was significantly strengthened through their feedback.

An Alternative Approach

While I recommend that the school district adopt the building-by-building approach outlined in this
memo, a viable alternative would be to retain the district-wide mask requirement until the level of
community transmission of the virus in Olmsted Country reaches the Medium level. At that level, the
CDC guidelines call for making masks recommended but not required. At present, Olmsted County is
still at a high level of transmission. While this approach would fully align our school district’s policies
with the CDC guidance, I recommend we instead adopt the building-by-building approach outlined
here because levels of Covid in Rochester Public Schools – as opposed to Olmsted County as a
whole – are very low and because other mitigation strategies will be in place to stop the spread of
615 7th St. SW, Rochester, MN 55902-2052 | 507.328.4256
Covid in our schools, including requiring masks when more than 5% of students and staff test positive
and transitioning classrooms, grade levels and entire schools to distance learning as outlined in the
RPS Safe and Open Schools Plan.

Timeline and Process for Making a Decision

For reasons outlined below, it is my hope to implement the approach to face coverings summarized in
this memo starting Monday, March 7, 2022. Implementation of our new approach on that date would
provide school staff and parents with several days to prepare for the shift, but it would not amount to
an extended period of time during which students would be asked to adhere to a policy that they
know is eventually going to change.

I recommend that the School Board put this shift in motion through passage of a resolution at its
regular meeting on March 1, 2022. Action on such a resolution would provide board members with
the opportunity to indicate their support for the shift in our processes outlined in this memo. With that
resolution in place, we would implement a change in our practices regarding face coverings starting
on March 7, and the School Board could consider formally changing School Board Policy 808 (which
governs our approach to face coverings during the COVID-19 pandemic) at the regular School Board
meeting on March 22, 2022.

A resolution that the School Board passed on September 7, 2021, gives the superintendent the
authority to shift our approach to face masks before the School Board formally considers a change in
school district policy. The two relevant provisions of that resolution are:

BE IT FURTHER RESOLVED that the School Board of Independent School District

#535 authorizes the Superintendent, after consultation with the School Board Chair and
notification to the School Board, to select and implement different face covering
requirements for the School District or any specific school buildings without School
Board action if the Superintendent reasonably believes that prompt implementation of
different face covering requirements are necessary, and that constraints of time and
public health considerations render it impractical to hold a School Board meeting to
approve the implementation; and

BE IT FURTHER RESOLVED that the School Board of Independent School District

#535 authorizes that the face covering requirements selected and implemented by the
Superintendent shall continue in effect unless and until the School Board, in
consultation with the Superintendent and appropriate school district staff and public
health officials, deems it in the best interest of the School District and its students to
implement different face covering requirements.

Rationale

I believe this is the appropriate time to shift our approach to face coverings in Rochester Public
Schools for the following reasons:

1. The rate of positive Covid-19 cases in our community is declining dramatically. For example,
the rate of positive cases per 100,000 people in Olmsted County was 1,741.71 the week of
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 February 3rd, 526.87 the week of February 17, and 271.02 the week of February 24. It is also
important to note that, despite this decline, Olmsted County remains at a high level of
community-wide transmission according to the updated framework from the Centers for
Disease Control that was released on Friday, February 26.

2. While the number of cases in Olmsted County remains at the high level, the number of Covid
cases in Rochester Public Schools has declined significantly from the peak of the pandemic
and is likely to continue to decrease. For example, during the week of January 10, 2022, 756
RPS students and staff tested positive for Covid, while during the week of February 14, only
127 cases were reported. 63 cases were reported during the week of February 21. Notably,
the downward trend in our case counts continued after we ceased contact tracing and
quarantining close contacts on Monday, February 14. I believe, along with our internal core
Covid team, that we can safely discontinue our mask requirement at this level of transmission
with the important provision that masks will be required for two weeks in any RPS facility
where 5% or more of the students and staff test positive for Covid-19.

3. Rates of serious illness and hospitalization among RPS students have been extremely low
throughout the pandemic and we are unaware of any students or staff who are extremely ill or
hospitalized due to Covid-19 at this time.

4. While wearing masks is an invaluable tool when Covid rates are high, relatively few RPS
students have chosen or indicated that they are willing and able to wear the type of high-
quality mask (such as an N95 or a KN95 mask) that studies have shown provides the greatest
protection.

5. Covid vaccination rates are very high in many RPS schools and we are continuing to
encourage vaccination in schools where those rates are lower. On average, as of February 27,
63.48% of all students in our secondary schools and 44% of students in our elementary
schools are fully vaccinated according to the database maintained by the State of Minnesota.

6. While very few, if any, high-quality studies of the impact that wearing masks has on students’
academic, social, and emotional development have been conducted to date, my discussions
with and observations of students and staff throughout RPS confirm that the impact is not
insignificant. At minimum, development of language and reading facial expressions and other
cues to social and emotional wellbeing are likely affected to some degree by covering a large
portion of the face. Without question, those and other tradeoffs should be made when Covid
case rates are high to slow or stop significant spread of the virus. However, the potential
educational, social, and emotional consequences of requiring all students and staff to wear
masks should be given greater weight when case rates are comparatively low.

7. While I do not believe that Rochester Public Schools should determine its approach to face
coverings or any other aspect of mitigating the spread of Covid-19 based upon the policies of
other school districts, any effort to protect public health must consider the context within which
mitigation strategies are being implemented. Because a growing number of school districts in
Minnesota have already or soon will move away from mask requirements, the willingness of
Rochester students to continue their strong adherence to our mask requirement is likely to
wane in the weeks ahead if we maintain that requirement without change. For example, there
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 are two major consortia of school districts of which Rochester Public Schools is a member: the
Big Nine athletic conference of school districts in southern Minnesota and the Association of
Metropolitan School Districts (AMSD) across the state. Significant shifts in mask requirements
have already occurred across both of those consortia and additional shifts are expected in the
weeks ahead:

• Within the Big Nine conference, the following school districts do not require students and
staff to wear masks: Albert Lea, Austin, Faribault, Mankato, Northfield, Owatonna, and Red
Wing.

• The two school districts within the Big Nine that currently require masks are Rochester and
Winona. Winona’s mask requirement will be discontinued on Monday, March 7, 2022.

• Within AMSD, the following school districts do not require the wearing of masks as of
February 24, 2022, based upon a survey of member districts: Anoka-Hennepin, Eden
Prairie, Edina, Elk River, Farmington, Hastings, Mahtomedi, Orono, Osseo, Prior Lake-
Savage, Rockford, Shakopee, South Washington County, Southwest Metro Intermediate,
Spring Lake Park, Stillwater, Wayzata, and White Bear Lake.

• Based upon the same survey, the following AMSD school districts continue to require
masks: Bloomington, Brooklyn Center, Burnsville-Eagan-Savage, Columbia Heights, Inver
Grove Heights, Minnetonka, Northeast Metro 916, Richfield, Robbinsdale, Rochester,
Rosemount-Apple Valley-Eagan, Roseville, Saint Paul, South Saint Paul, St. Anthony-New
Brighton, Saint Louis Park, West Saint Paul-Mendota Heights-Eagan. The superintendents
of 57% of the school districts that require masks reported that they are planning to
transition to a less restrictive masking policy, while 43% of the superintendents of districts
that require masks reported that they were not considering making such a transition.

• 14 AMSD school districts did not respond to the survey.

Conclusion

This is a difficult decision that I look forward to discussing with School Board members at the regular
meeting on Tuesday, March 1, and beyond. I hope that the recommendation I have outlined here will
be seen not as the end of requiring face coverings in all Rochester Public Schools facilities, but as a
shift from a district-wide approach to a building-by-building approach that will be driven by actual
Covid case rates in the schools and programs where our students and staff learn and work each day.

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