Dear County Executive McCoy,

We want to start by acknowledging the work the Albany County Department of Health has done with the vaccination rollout and keeping our community safe. Given that the pandemic shows no signs of ending and that young children are prone to seasonal illnesses that share symptomatic similarities with COVID-19, we, the parents and guardians of Albany County school children, request that the Albany County Department of Health and the Albany County Executive Office:

1. Create safe, drive-thru NAAT/PCR lab testing options that prioritize children and child care workers; that are performed by trained technicians; that do not require appointments; that provide results within 24-36 hours; that are free to people without health insurance; and that are accessible by public transportation.

2. Accept confirmatory testing: when students and child care workers test positive for COVID via rapid tests, the diagnosis should be confirmed via a NAAT/PCR lab test to determine if a quarantine is warranted. 

3. Update guidance for school nurses: if a student has a chronic, medically documented condition and the school has that documentation, children should be treated for the condition rather than sent home for COVID testing.

Summary:

1.There is a lack of safe, accessible drive-thru testing sites for NAAT/PCR lab tests, which are required for symptomatic children to return to school.

COVID-19 testing options for children are currently limited to walk-in facilities, pediatricians’ offices, and pharmacies. Many pharmacies offer drive-thru testing by appointment only. Unfortunately, most appointments are booked days in advance, forcing parents or guardians to utilize walk-in testing facilities or pediatricians' offices, where turnaround times for results can take anywhere from 24 hours to five days.(1) Furthermore, children under the age of 3 are rarely eligible for pharmacy drive-thru testing. (2)

In addition to pharmacy drive-thru appointments being difficult to schedule, many of them are also located some distance from the families who need them. They sometimes require an hour round trip(3), not including wait time, and require families to have their own transportation.

2. Walk-in testing sites are an exposure risk to unvaccinated young children, and especially to those unable to wear a mask. They often require long wait times.

In order to get test results as quickly as possible, working parents or guardians must utilize walk-in testing sites for their children or wait multiple days for an appointment at a drive-thru pharmacy or at the pediatrician’s office. Not only do these walk-in testing site facilities often have long wait times, but there is no priority for young children who may be unvaccinated and/or cannot wear a mask properly. In order to get children back to school and parents and guardians back to work, families must risk exposing their children to COVID-19 and other illnesses at walk-in testing sites. 

Many pediatricians’ offices have expressed being overwhelmed and have not had same-day appointments available for testing.(4)

4. Children with disabilities need equal testing access to NAAT/PCR testing sites. 

Children with disabilities often require additional accommodations for regular doctor visits. This is also the case at testing facilities. For example, a child who is Autistic may have a difficult time being in a different environment, waiting in line, and wearing a mask. Exposing them to test sites can prove very difficult. Parent-administered tests for pharmacy drive-thru appointments can also be challenging if the child requires restraint during an unfamiliar and potentially upsetting test procedure.(5)

5. Research shows that school attendance is an important factor in student achievement(6). Longer wait times for results equals more time that children are required to stay out of school.

Children are missing 1-2 additional days of school waiting on results even when they are symptom-free. This has a negative effect on children, especially on children who are receiving services such as occupational therapy, speech therapy, and physical therapy--services that are crucial to their success, development, and overall well-being. It also negatively impacts working parents and guardians who must miss work to care for children awaiting test results.  A 24-36 hour turnaround for NAAT/PCR lab results can not only reduce the spread of positive cases, but also help symptom-free children return to school quickly. 

Also concerning is that, when a quarantine order goes into immediate effect, quarantined children are publically removed from their classrooms without being given any context or information regarding their removal. This has caused elementary school children distress and fear that they are in trouble. We ask that when children are removed from their classrooms, it be done discreetly and that students be given context for their removal. 

6. Rapid testing at schools does not fill the need for PCR/NAAT drive-thru testing. 

While some Albany County school districts are beginning to randomly sample students using rapid antigen tests, this testing does not mitigate the need for accurate, safe drive-thru testing that provides NAAT/PCR lab results reliably in 24-36 hours. 

Because a negative NAAT/PCR test result is required for symptomatic children to return to school, the need for accurate, safe, free, time-sensitive, and accessible testing sites remain. 

7. NAAT/PCR labs collected at or near the same time as rapid point-of-contact tests should override any rapid test results. 

Research shows that rapid tests can have a high false-positive rate if contaminated or not properly handled(8). Because NAAT/PCR lab tests are more sensitive and are run in laboratories with stricter protocols than point-of-contact sites, they should be used to confirm any rapid test results in symptomatic or asymptomatic children. As more school districts, including the Bethlehem Central School District, begin to incorporate rapid sample testing, there is likely to be a rise in both positive and false positive cases. In order to avoid unnecessary quarantines, these results must be confirmed by NAAT/PCR lab testing.

8. If a student has a documented, chronic condition, they should be able to be treated by school nurses without being sent home to obtain NAAT/PCR lab results. 

Students are being sent home for chronic, documented conditions such as migraines, food sensitivities, allergies, and motion sickness. This places an unfair burden on children with chronic conditions and their parents/guardians. It also discourages children from going to the school nurse for medical treatment.  

.....

We are hopeful that with continued communication between the County, school districts, and district families, we can establish an accessible and equitable testing system that relieves the current burden on students and parents. 

Per communication with the Bethlehem Central School District and the Albany County Executive office October 28th and November 29th, BCSD had declined to use the County-led testing program due to staffing restraints. We have not received a follow up communication regarding our request on the safe-drive thru testing after this correspondence. Correspondence will be provided upon request.

Thank you for your time and consideration in addressing our concerns:

Nicole Collins collins.nicolek@gmail.com
Courtney Ryan crdram12@gmail.com

1. See Albany County’s “List of testing sites in Albany County”: https://www.albanycounty.com/departments/health/coronavirus-covid-19/testing-results
2. See, for example, CVS, Walgreens, and Rite Aid. 
3.  Example: Son of Nicole Collins, November 2021
4.  https://www.news10.com/news/local-news/covid-19-protocols-keep-pediatricians-busy/
5. Example: Son of Nicole Collins, September, October, and November 2021
6.  https://nces.ed.gov/pubs2009/attendancedata/chapter1a.asp
7. Multiple parents mentioned this during  the comment period for this petition. 
8. https://www.fda.gov/medical-devices/letters-health-care-providers/potential-false-positive-results-antigen-tests-rapid-detection-sars-cov-2-letter-clinical-laboratory

See our full letter here with footnotes: https://docs.google.com/document/d/1AzhrBrL2qgUVfaSCOsR6lpHTp7EcgpIYhGtELSsLZQE/edit?usp=sharing