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The COVID Project

How an Education or Child Care Employer Operates

The functions

An education or child care employer sells presence. It earns tuition by putting a teacher and a group of students in a room, a laboratory, a studio, a gymnasium or a playing field; it earns weekly fees by caring for children in rooms whose ratios its license fixes; it earns auxiliary revenue by housing, feeding and transporting students and by renting its facilities; and every one of those activities is a group meeting, most of them involve travel, and all of them are commerce. The industry performs twelve functions, each at a place, with a counterparty, on an input that a governmental order can reach and did reach. The customer base is the family, and every family in the country was itself under orders.1

IN, in-person instruction

The core service is a class taught in a building to students who are physically present: a kindergarten of twenty children, a chemistry laboratory, a dance studio, a driving lesson, a seminar of twelve, a lecture of three hundred. Tuition is earned by delivering it. An order that closes school buildings to students, that suspends "normal in-person instruction," that fixes the earliest date on which in-person instruction may begin, that bars in-person instruction in counties on a monitoring list, that confines classrooms to cohorts of a fixed size, that requires six feet or three feet between desks, that requires a face covering of every person in the room as one of its exposure-control conditions, or that excludes a class for ten to fourteen days after an exposure, changes what the classroom does and how many children can be in it.2

RL, remote learning

Remote learning is the compelled substitute of March 2020, not a business the industry sold. It requires devices, connectivity, a redesigned schedule, redesigned assessment, retrained staff and a different relationship with every family; it earns no laboratory fee, no studio fee, no athletic fee, no dormitory rent and no dining revenue; and for a child care center or a preschool it does not exist, because a two-year-old cannot be cared for by video. The orders that closed the classroom compelled the switch, the orders that gated reopening compelled its continuation, and the orders of the 2020-21 year (metrics, hybrid models, cohort rules, quarantine rules) compelled schools to run two systems at once.3

EC, extended care and child care

Before-school and after-school care, preschool, infant and toddler rooms and summer programs are the revenue lines most exposed to orders, because their capacity is set by licensed ratios and their customers are working parents. In March and April 2020 at least twelve States and the District of Columbia closed child care to all but the children of essential workers or permitted only newly certified emergency programs to operate; the others imposed group-size and ratio rules that cut licensed capacity by half or more; from May 2020 the reopening orders conditioned every room on cohorts of ten or fewer, screening, exclusion and face coverings; and in 2021 the school and child care orders of Kentucky, Delaware, New Jersey, Illinois, Connecticut, Denver and the District of Columbia, which imposed universal face coverings with screening, exclusion and quarantine requirements on every licensed room, and the staff vaccination-or-testing orders of Connecticut, Washington, New Jersey, New York City and the District reached child care by name.4

TR, transport

Schools own or contract buses, run car lines and take field trips; colleges run shuttles. A school bus is a conveyance. The 2020 closure orders idled every route; the 2020-21 school orders extended their infection-prevention requirements to every rider, a face covering in the States that required one in the classroom and capped seating where the distancing rules applied; from February 1, 2021 the federal conveyance order, an airborne-transmission control on every conveyance in the United States, required a mask of every passenger and operator, school buses included, on every day through September 30, 2021; and the 2021-22 school orders reached "vehicles used for transportation such as school buses" in terms.5

FS, food service

Cafeterias serve congregate meals reimbursed under the National School Lunch Program and the Child and Adult Care Food Program; colleges run dining halls on board contracts. The closure orders ended congregate feeding and left schools serving meals at the curb or not at all; the federal government waived the congregate-feeding requirement nationwide for school years 2019-20, 2020-21 and 2021-22 because the schools could not comply with it; and the reopening orders required meals in classrooms, staggered lunches and distanced seating.6

AC, athletics, activities and events

Interscholastic sports, arts performances, assemblies, dances, graduations, fundraisers, camps and facility rentals are revenue lines and the reason many families pay tuition. Michigan suspended every K-12 sport and extracurricular activity "while any state of emergency or state of disaster prompted by COVID-19 is in effect"; Minnesota paused organized youth sports from November 21, 2020 to January 4, 2021; New Mexico's Activities Association cancelled the spring 2020 seasons and postponed the fall 2020 seasons because the Governor's public health order barred them; West Virginia barred every youth winter sport from November 13, 2020 and every sport from practice until February 14, 2021 and from competition until March 3, 2021; Massachusetts ran mandatory sector rules for youth sports from July 6, 2020 to May 29, 2021; the gathering limits of every State governed every assembly, graduation and game; and the camp orders of 2020 fixed whether a summer program could open at all.7

AD, admissions, tours and enrollment

Open houses, campus visits, entrance testing, enrollment fairs and international recruitment fill next year's seats. The stay-at-home orders closed the campuses to visitors; the entry proclamations and the suspension of routine visa services closed the pipeline of new international students for fall 2020; the Student and Exchange Visitor Program's broadcast messages of March 9 and July 6, 2020 fixed the terms on which an F-1 student could remain in the United States while taking online courses; and fall 2020 first-time enrollment fell 13.1 percent nationally.8

CP, campus housing and dining

Boarding schools and colleges earn room and board. The March 2020 orders emptied the dormitories and dining halls of every campus that ceased in-person instruction; the reopening orders of 2020 and 2021 fixed the conditions of residential life (single rooms, cohorts, testing, quarantine housing, closed dining rooms); Denver's public health orders for institutions of higher education ran from October 16, 2020 to April 23, 2021; Washington's Proclamation 20-12 series governed campus operations from March 20, 2020 through the third quarter of 2021; and the entry orders determined which international students could occupy the beds.9

HR, hiring, screening, training and credentialing

The industry hires by background check, fingerprinting, certification and licensure, runs substitute pools, and screens every adult who enters a building. The 2020 orders closed the fingerprinting and licensing offices and suspended the testing on which certification depends; the 2020-21 orders required daily screening, exclusion and testing of staff; the 2021 orders required every school and child care employer in California, Washington, Oregon, New Mexico, Connecticut, New Jersey, Illinois, New York and the District of Columbia to verify the vaccination status of every worker and to test the unvaccinated weekly, and Washington's and Oregon's orders barred the unvaccinated from working at all after October 18, 2021.10

OP, office, administration and telework

Business offices, admissions offices and front desks were reached by the general telework and workplace orders of every State: New York's one-hundred-percent in-person workforce reduction, Oregon's prohibition of office work "whenever telework and work-at-home options are available," the State workplace standards of California, Virginia, Oregon, Washington and Michigan, and the reopening orders' occupancy caps, screening and masking rules.11

WF, workforce availability

The workforce is teachers, professors, aides, child care teachers, bus drivers, food service and custodial staff, coaches and office staff, predominantly women, many with school-age children of their own. Every school-closure order was therefore an order on the industry's own workforce as well as on its customers; the quarantine and isolation orders removed exposed and infected staff for ten to fourteen days at a time; the Families First Coronavirus Response Act compelled paid leave from April 1 to December 31, 2020 for every employee under a quarantine order or caring for a child whose school or place of care an order had closed; and the 2021 staff vaccination-or-testing orders fixed who could work.12

CB, families, the customer base and its payers

The customers are families, the employers of those families, school districts that contract for transportation, food, tutoring and special-education services, and the State and federal agencies that pay child care subsidies, Head Start grants and child nutrition reimbursements. A stay-at-home order on the family, a telework order on its employer, a closure order on the district that contracts for the service, and a federal rule that alters the terms of the subsidy each limited the commerce of this industry directly.13

Revenue lines, seasonality and geography

Revenue is tuition and fees billed by term or by week; auxiliary revenue from housing, dining, bookstores and parking; extended-care and summer fees; athletics and events (gate, food-stand and merchandise sales, rentals); child nutrition reimbursements; child care subsidies and Head Start grants; tutoring fees by session or package; and donations and annual funds. The academic year runs from August or September to May or June; the admissions season (January through April) fell inside the spring 2020 closures; the summer camp and summer child care season (June through August) fell under the 2020 camp orders and the 2020 reopening conditions; and the fall 2021 start fell inside the Delta-wave orders of July through September 2021. Child care operates year-round on weekly tuition with ratios set by license, so that a ratio or cohort order cuts capacity and revenue directly. The industry operates in every county in the United States, and its largest concentrations are in the metropolitan areas whose local orders the layer inventory below sets out.14

The counterparty map

Families and their employers: the stay-at-home, telework and workplace orders of every State and metro, and the federal paid-leave mandate that made a school or place-of-care closure a qualifying reason for leave. State licensing agencies: the emergency child care rules, ratio and group-size orders, emergency licenses and disaster relief centers of 2020 and the emergency face-covering and vaccination regulations of 2021. State health departments: the communicable-disease orders, the school face-covering and exposure-control orders, the quarantine and isolation standing orders and the reporting orders. Departments and boards of education: the closure directives, remote-learning declarations, reopening frameworks, instructional-time rules and 2021 face-covering regulations. Athletic associations: the cancellations and postponements that followed the States' orders. Bus contractors and food distributors: the conveyance order, the contract terms of closed districts and the nationwide meal waivers. Landlords and host churches: the worship-gathering orders that governed the buildings in which many preschools operate. The international pipeline: the Student and Exchange Visitor Program, the consular suspensions and the entry proclamations. The payers: the Administration for Children and Families' Head Start and child care instruments and the Food and Nutrition Service's waivers. The layer inventory below sets out each class.15

  1. The size figures are at Ex. SEC-15-009 and Ex. SEC-15-010; the industry-condition surveys at Ex. SEC-15-006 and Ex. SEC-15-007. The function codes, revenue lines, counterparties and workforce description are those of the Library's sector record for education and child care. ↩
  2. The classroom orders are inventoried in the layer inventory below and applied in the quarters and functions sections; for the categories named here, see Ex. SEC-15-076 (Colorado: "shall suspend normal in-person instruction"); Ex. SEC-15-019 and Ex. AZ-021 (Arizona: earliest in-person start); Ex. SEC-15-053 (California: no in-person instruction in monitoring-list counties); Ex. IL-020 (Illinois: fifty or fewer per space); Ex. NJ-032 (New Jersey: six feet and face coverings as conditions of in-person instruction); Ex. AL-047 (Alabama: three feet between students); Ex. IL-045 and Ex. IL-072 (Illinois: exclusion of cases and close contacts); Ex. RI-060 (Rhode Island: quarantine and isolation). ↩
  3. Ex. AGY-ST-EDUCATION-HIGHER-ED-033 (Illinois Remote Learning Days declared statewide from March 31, 2020) and Ex. AGY-ST-EDUCATION-HIGHER-ED-012 (the State Board's Remote Learning Recommendations of March 27, 2020; guidance implementing the declaration and the emergency rule, cited as context); Ex. AGY-ST-EDUCATION-HIGHER-ED-030 (23 Ill. Adm. Code Part 5 emergency rule); Ex. MN-009 and Ex. MN-016 (Minnesota Distance Learning Period); Ex. OR-014 (Oregon: distance learning for all through the 2019-20 year); Ex. NH-002 (New Hampshire: temporary remote instruction); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-005 and Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-007 (Chicago Remote Education Policy, June 23 and Aug. 25, 2021); Ex. WA-045 (Washington Proclamation 20-70, transportation and remote learning). ↩
  4. Ex. SEC-15-012 (New Jersey EO 110); Ex. SEC-15-071 ¶ 5 (Ohio: child care closed Mar. 26 to May 31, 2020 except pandemic licensees, the closure order recited and rescinded in the May 31, 2020 reopening order); Ex. MA-006 and Ex. MA-013 (Massachusetts Orders No. 10 and 27: child care closed Mar. 23 to June 29, 2020 except exempt emergency programs); Ex. PA-083 (Pennsylvania: centers closed from Mar. 17, 2020 except waived providers); Ex. MD-034 (Maryland: child care closed to non-essential families from Mar. 27, 2020); Ex. DE-011 (Delaware: emergency child care sites only from Apr. 6, 2020); Ex. VT-005 (Vermont: child care for essential persons' children only from Mar. 18, 2020); Ex. OR-013 (Oregon EO 20-19: emergency child care only); Ex. ECO-B-081 (Illinois: day care centers closed except emergency child care); Ex. KY-070 (Kentucky: groups of ten); Ex. WY-004 (Wyoming: child care facilities closed Mar. 19, 2020); Ex. DC-083 (District of Columbia: provider closures from Mar. 13, 2020); Ex. SEC-15-049 (Michigan disaster relief child care centers); Ex. CA-046 (California PIN 20-06-CCP: essential-worker priority and group sizes); Ex. MO-045 (Boone County: child care stable groups); Ex. MET-SAN-003 (San Diego County: stable groups of ten); Ex. NH-052 (New Hampshire child care reopening guidance, mandatory to May 7, 2021); Ex. RI-089 (Rhode Island DHS child care plan); Ex. LA-052 (Louisiana child care checklist by phase); Ex. SEC-15-080 (Kentucky 2021: "all child care settings"); Ex. KY-054 (902 KAR 2:213E); Ex. DE-045 and Ex. DE-066 (Delaware 2021 child care face-covering orders); Ex. NJ-058 (New Jersey EO 264); Ex. IL-040 (Illinois EO 2021-18: day care centers); Ex. CT-054 (Connecticut EO 13D: childcare facility staff); Ex. MET-DEN-024 (Denver: child care facilities); Ex. SEC-15-043 (Washington: child care workers); Ex. MET-NYC-043 (New York City: contracted early-education and child care staff); Ex. DC-076 (District of Columbia: child care personnel). ↩
  5. Centers for Disease Control and Prevention, Requirement for Persons To Wear Masks While on Conveyances and at Transportation Hubs, 86 Fed. Reg. 8025 (Feb. 3, 2021) (signed Jan. 29, 2021; dated Feb. 1, 2021; effective 11:59 p.m. Feb. 1, 2021) (Ex. FED-020; Ex. ECO-B-004); Ex. SEC-15-069 ¶ 1(d) ("Riding a school bus"); Ex. SEC-15-080 ¶ 2 ("including but not limited to inside of vehicles used for transportation such as school buses"); Ex. UT-019 (Utah: face coverings in K-12 schools and school buses); Ex. SC-057 (South Carolina: face coverings on school buses, 2020-21); Ex. RI-057 (Rhode Island EO 21-90, Student Transportation Order, Aug. 26, 2021); Ex. IN-018 (Indiana: bus-inspection decals); Ex. MET-ATL-065 (Clayton County: masks required on the school bus, 2021-22). ↩
  6. Food and Nutrition Service, Agency Information Collection Activities: FNS Information Collection Needs due to COVID-19 (Aug. 27, 2020) (Ex. AGY-FED-HEALTH-OTHER-100) (describing the FFCRA § 2202 waiver regime in effect from March 2020); Food and Nutrition Service, School Meals Operations Study: Evaluation of the COVID-19 Child Nutrition Waivers (Apr. 21, 2021) (Ex. AGY-FED-HEALTH-OTHER-101) (nationwide waivers in use in school years 2020-21 and 2021-22); Food and Nutrition Service, Pandemic Electronic Benefits Transfer (P-EBT) Integrity, final rule (Nov. 4, 2020) (Ex. AGY-FED-HEALTH-OTHER-098) (benefits keyed to schools and child care reducing days or hours); Ex. SEC-15-011 ¶ 4 (New Jersey: schools permitted to remain open "on a limited basis for the provision of food"); Ex. SEC-15-025 § 1 (Illinois: closure "does not affect the availability of school buildings for the provision of food"); Ex. SEC-15-020 ¶ 8 (Minnesota: "schools are expected to provide meals to their students"); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-029 (Los Angeles Unified: 20 million meals served during the closure). The non-congregate waiver for school year 2021-22 (FNS Child Nutrition Response #85, Apr. 20, 2021) is described by category. ↩
  7. Ex. SEC-15-051 § I.A (Michigan); Ex. MN-032 (Minnesota EO 20-99); Ex. AGY-ST-EDUCATION-HIGHER-ED-039 and Ex. AGY-ST-EDUCATION-HIGHER-ED-040 (New Mexico Activities Association, Mar. 27 and Oct. 12, 2020); Ex. WV-054 and Ex. WV-056 (West Virginia EOs 80-20 and 2-21); Ex. WV-037 and Ex. WV-039 (West Virginia EOs 43-20 and 45-20: school athletics and graduation ceremonies); Ex. AGY-ST-EDUCATION-HIGHER-ED-036 (Massachusetts youth and adult amateur sports rules, July 6, 2020 to May 29, 2021); Ex. AGY-ST-EDUCATION-HIGHER-ED-015 (California youth sports, Dec. 14, 2020); Ex. NE-036 (Nebraska sports reopening guidelines, June 1, 2020); Ex. AR-072 and Ex. AR-071 (Arkansas team sports and school music and theater directives); Ex. MT-046 (Yellowstone County school-sanctioned sports order, Aug. 18, 2020); Ex. MS-035 and Ex. MS-052 (Mississippi: K-12 extracurricular events limited); Ex. TN-029 (Tennessee EO 74: spectators at school sports) and Executive Order 70, cited by name; Ex. DC-080 (District of Columbia: high-contact sports prohibited); Ex. MET-DEN-086 (Jefferson County: P-12 access and sports); Ex. AR-046 and Ex. AR-085 (Arkansas: camps cancelled, then day camps under conditions); Ex. SEC-15-013 (New Jersey: camps from July 6, 2020 under standards); Ex. SEC-15-062 (Vermont: gatherings capped at fifty). ↩
  8. Ex. SEC-15-004 and Ex. AGY-FED-LABOR-IMMIGRATION-070 (SEVP Broadcast Message 2003-01, Mar. 9, 2020); Ex. SEC-15-005 and Ex. AGY-FED-LABOR-IMMIGRATION-072 (SEVP Broadcast Message 2007-01, July 6, 2020, rescinded July 14, 2020); Ex. AGY-FED-LABOR-IMMIGRATION-071 and Ex. AGY-FED-LABOR-IMMIGRATION-073 (SEVP's follow-up message of July 24, 2020 and its FAQ, first issued March 2020, continuing the March 9, 2020 terms; guidance and a service announcement, cited as context for the Broadcast Message, Ex. AGY-FED-LABOR-IMMIGRATION-070); Ex. FED-200; Ex. FED-201; Ex. FED-207; Ex. FED-208 (Proclamations 9984, 9992, 10143 and 10199); Ex. FED-042 (pre-departure test order); Ex. SEC-15-007 (fall 2020 enrollment). ↩
  9. Ex. SEC-15-011 ¶ 3 and Ex. SEC-15-018 (New Jersey higher education: cessation Mar. 18, 2020; restart from July 1, 2020 under mandatory standards including housing, dining and transportation); Ex. WA-008; Ex. WA-038; Ex. WA-046; Ex. WA-071; Ex. WA-074; Ex. WA-081 (Washington Proclamation 20-12 series); Ex. OR-059; Ex. OR-060; Ex. OR-021 (Oregon EOs 20-09, 20-17 and 20-28); Ex. MET-DEN-037 and Ex. MET-DEN-015 (Denver institutes of higher education, Oct. 16, 2020 to Apr. 23, 2021); Ex. MN-019 and Ex. MN-029 (Minnesota EOs 20-52 and 20-85); Ex. RI-033 (Rhode Island EO 21-04); Ex. AGY-ST-EDUCATION-HIGHER-ED-027 (State University System of Florida, Mar. 17, 2020); Ex. AGY-ST-EDUCATION-HIGHER-ED-051 (University of California, Mar. 17, 2020); Ex. AGY-ST-EDUCATION-HIGHER-ED-009 (California institutions of higher education guidance, Aug. 7, 2020); Ex. AGY-ST-EDUCATION-HIGHER-ED-046 (Utah: testing of every student in campus housing); Ex. NY-112 (New York interim guidance for higher education, June 26, 2020 to June 25, 2021); Ex. AGY-ST-EDUCATION-HIGHER-ED-065 (Iowa Board of Regents, revenue loss report, Apr. 30, 2020). ↩
  10. Ex. WA-022 (Washington Proclamation 20-31: child care and background checks); Ex. ND-055 (North Dakota: substitute-teacher limits suspended); Ex. NE-047 and Ex. NE-053 (Nebraska EOs 20-08 and 20-18: child care provider rules); Ex. OK-029 (Oklahoma: Third Amended Executive Order 2020-20, July 30, 2020, directing the teacher and support-employee testing plan by Aug. 21, 2020); Ex. SEC-15-023; Ex. SEC-15-043; Ex. OR-052; Ex. SEC-15-034; Ex. SEC-15-016; Ex. SEC-15-027; Ex. NM-068 and Ex. NM-071 (New Mexico school workers, from Aug. 23, 2021); Ex. NY-072 and Ex. NY-075 (10 NYCRR 2.62); Ex. SEC-15-037; Ex. DC-076; Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-052 (Fairfax County Public Schools staff vaccination requirement, Aug. 23, 2021); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-017 (Prince George's County Public Schools: employee vaccination-or-weekly-testing, Sept. 8, 2021). ↩
  11. Ex. NY-011 (New York EO 202.4: local-government telework from Mar. 17, 2020); Ex. OR-007 (Oregon EO 20-12: "Work in offices is prohibited whenever telework and work-at-home options are available"); Iowa's proclamation of Nov. 11, 2020 (all employers to enable remote work where feasible), cited by name; Ex. ECO-B-045 (Virginia 16VAC25-220 emergency temporary standard, July 27, 2020); Ex. ECO-B-121 (Washington Proclamation 20-46); Ex. SEC-15-077 ¶ 2 (Ohio: "Telework options should be explored and encouraged whenever feasible"). The general telework and workplace orders of every State are inventoried on the Professional and Information Services page and are cited here by category. ↩
  12. Families First Coronavirus Response Act, Pub. L. 116-127, 134 Stat. 178 (Mar. 18, 2020) (Ex. FED-170; Ex. ECO-B-001); Department of Labor, Paid Leave Under the Families First Coronavirus Response Act, 85 Fed. Reg. 19326 (Apr. 6, 2020) (Ex. FED-171; Ex. ECO-B-002; Ex. AGY-FED-LABOR-IMMIGRATION-001) (29 C.F.R. § 826.20(a)(1)(i) and (v): leave for an employee subject to a quarantine or isolation order and for an employee caring for a child whose school or place of care has been closed); revised rule, 85 Fed. Reg. 57677 (Sept. 16, 2020) (Ex. FED-172; Ex. ECO-B-003; Ex. AGY-FED-LABOR-IMMIGRATION-002); Ex. SEC-15-009 (child day care employment); Indiana's 410 IAC 1 control measures (isolation and quarantine), cited by name; Ex. MET-SAN-023 and Ex. MET-SAN-024 (San Diego County isolation and quarantine orders); Ex. MET-STL-067 (St. Louis County Sixth Amended Quarantine and Isolation Order); Ottawa County's isolation and quarantine order in educational settings (Aug. 6, 2021), cited by name; Ex. SC-062 (South Carolina school and child care exclusion list, 2021-22); Ex. VT-074 (Vermont: schools to issue quarantine letters, Aug. 19, 2021). ↩
  13. Ex. AGY-FED-HEALTH-OTHER-089 (Head Start designation renewal flexibility, Dec. 7, 2020: "Many Head Start classrooms across the country closed"); Ex. AGY-FED-HEALTH-OTHER-093 (ARP Act child care stabilization grants); Ex. AGY-FED-HEALTH-OTHER-098 (P-EBT); Ex. AGY-FED-HEALTH-OTHER-101 (child nutrition waivers); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-001 and Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-006 (Chicago Board of Education emergency expenditure resolutions of Mar. 25, 2020 and July 28, 2021, governing the District's contracts); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-045 and Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-046 (Houston Independent School District: closure Mar. 13, 2020; virtual instruction for the first six weeks of 2020-21); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-050 (Fairfax County Public Schools: virtual start Sept. 8, 2020); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-013 (Prince George's County Public Schools: distance learning from Aug. 31, 2020) (the three districts' announcements, cited as the record of the decisions they report and not as orders); Ex. AGY-LOCAL-DISTRICTS-AUTHORITIES-028 (Los Angeles Unified: emergency authorization, Mar. 10, 2020; schools closed to students from Mar. 16, 2020). ↩
  14. Ex. SEC-15-009; Ex. SEC-15-010; Ex. SEC-15-006 (70 percent of centers incurring substantial additional costs for staff, cleaning supplies and personal protective equipment). ↩
  15. The layer inventory below (the sector regulators; the counterparties; the ecosystem); Ex. FED-171 (the paid-leave trigger); Ex. AGY-FED-LABOR-IMMIGRATION-051 (Department of Education, waivers under CARES Act § 3511 granted to every State, 85 Fed. Reg. 29704 (May 18, 2020)); Ex. AGY-FED-LABOR-IMMIGRATION-084 (Department of Education, guidance for interruptions of study, Mar. 5, 2020, updated June 16, 2020); Ex. AGY-FED-LABOR-IMMIGRATION-085 (FERPA and COVID-19 FAQs, Mar. 2020). ↩