Audit Report on the Safety Measures Implemented by the New York City Department of Education in Response to the COVID-19 Pandemic

Executive Summary

We conducted this audit to determine whether the New York City (City) Department of Education (DOE) has: (1) identified the specific benchmarks for meeting and maintaining the cited standards for in-person instruction during the COVID-19 pandemic; (2) developed procedures for meeting those benchmarks; and (3) established an adequate framework to monitor whether those procedures are being followed.

DOE employs approximately 79,000 teachers and provides primary and secondary education to over one million students, from early childhood through 12^th grade, in 32 school districts. However, due to the COVID-19 pandemic, in-person instruction was suspended on March 16, 2020, and DOE schools transitioned to remote instruction for the rest of School Year 2019-2020.

As the COVID-19 pandemic continued for the start of School Year 2020-2021, DOE began the school year by offering a cohort-based approach where students would rotate between in-person and remote instruction. In connection with its phased resumption of in-person instruction during the pandemic, DOE established general standards for ensuring that in-person instruction at its schools could be conducted in a safe manner. For this audit, we focused on DOE’s standards related to enhanced cleaning and disinfection, necessary supplies—including personal protective equipment (PPE)—proper air quality/ventilation, and nursing coverage.

Audit Findings and Conclusion

This audit found that DOE has identified specific benchmarks for establishing whether schools have met DOE’s cited standards for being open for in-person instruction and developed procedures for its school-based personnel to meet those benchmarks. However, overall, DOE has not produced sufficient evidence that it can reasonably ensure that the agency’s COVID-19 procedures, particularly those relating to cleaning, disinfection, and air quality, are being carried out on a consistent basis in its hundreds of individual schools throughout the City. These weaknesses limit DOE’s ability to verify that its COVID-19 procedures are being followed and could lead to a false assurance of system-wide compliance, which in turn could increase the risk to some of the students and staff whom the procedures are intended to protect.

Specifically, we found that a key procedure relating to air quality within a school—the measurement of carbon dioxide levels with an indoor air quality (IAQ) monitor—is only optional, rather than a required aspect of DOE’s risk-mitigation procedures. Consequently, we have concerns about its effectiveness.

In addition, we found that DOE has not established an adequate framework of controls to monitor whether its procedures are being carried out. Specifically, DOE did not identify sufficient mechanisms to enable independent verification of whether its procedures are being followed in practice. Additionally, DOE’s management has not established sufficient mechanisms to enable confirmation of whether supervisory staff are monitoring the implementation of COVID-19 procedures.

Audit Recommendations

Based on our findings, we make seven recommendations, including:

• The Division of School Facilities (DSF) should implement a procedure for mandatory readings of carbon dioxide levels in indoor areas, such as classrooms, and require that such readings be adequately documented.
• The Division of School Climate and Wellness (DSCW) should develop a mechanism to enable it to confirm that nursing supervisors are fulfilling their responsibility to ensure that schools have adequate nursing coverage.
• DSF should consider establishing a set schedule for Deputy Directors to visit the schools assigned to them and a mechanism for ensuring that those visits are made.
• DSF should consider requiring that Deputy Directors certify their findings when they visit schools to ascertain schools’ compliance with COVID-19 procedures.

Agency Response

In its response, DOE generally agreed with the recommendation directed to DSCW and disagreed with the six recommendations directed to DSF. After carefully considering DOE’s response, we find no basis for modifying our report’s findings or recommendations.