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Legal Issues

COVID-19 FAQ: Homeless Shelters, Transitional Housing and Other Providers of Services to Homeless Individuals - March 16, 2020

As counsel to a number of Homeless Information Management System administrators, we were asked to address frequently asked questions from shelters and agencies who provide services to individuals experiencing homelessness. We understand there is widespread concern regarding how COVID-19 will impact your operations and the population you serve. 

This situation is rapidly changing as is the guidance from the CDC, public health officials, and regulators. We encourage you to contact your attorney should you have any questions or would like assistance developing your policies, procedures, communication pieces, and action plans.

1. What should shelters and agencies serving the homeless population be doing now to address the potential spread of COVID-19?

Even if COVID-19 is not spreading within your community, there is much you can and should do now to address the potential for community spread within your region. We recommend you access the CDC resources. Guidance available includes:

  • Interim Guidance for Homeless Shelters
  • Preventing the Spread of Coronavirus Disease 2019 in Homes and Residential Communities
  • Interim US Guidance for Risk Assessment and Public Health Management of Persons with COVID-19 Exposures
  • Interim Guidance for Implementing Home Care of People Not Requiring Hospitalization for COVID-19

COVID-19 presents many unique challenges for these shelters and agencies, because the population you serve cannot self-quarantine at home. Shelters and agencies should implement policies now to address clients who have been diagnosed or have been exposed to COVID-19 and take measure to limit the potential spread of COVID-19 within their communities.

We recommend reviewing the above referenced CDC resources and outline how you will address the following:

  • What precautions will we take to limit spread between staff, clients, and others?
  • If a client tests positive or is undergoing testing for COVID-19, how will we continue to serve this individual?
  • What staffing challenges might we face if there is community spread within our region and what alternatives can we implement to allow us to continue to provide services?

2. What specific precautions should a shelter or agency consider implementing?

Based on the CDC guidance, we recommend you implement the following precautions:

  • Post signs notifying clients, staff, and visitors of the signs and symptoms of COVID-19
  • Encourage your staff and volunteers who feel sick to stay home
  • Encourage personal protective measures among staff and clients, including hand washing and respiratory etiquette
  • Have staff clean surfaces frequently and ensure hand hygiene and cleaning supplies are readily available
  • Implement social distancing within your shelter/agency, including putting more distance between beds, putting more distance between individuals within the shelter/agency (such as at check-in, meals, etc.), staggering services, and changing food/dining options from buffet style to individual packaging
  • For shelters/housing providers: 
    • social distancing measures may impact the number of people you serve- consider reaching out to other local community organizations to identify whether they have space you can utilize to allow you to continue providing essential services while they are closed or what other assistance they may be able to provide
    • begin screening the individuals you serve for respiratory symptoms and fever, identify areas you can separate individuals who are symptomatic from individuals who are asymptomatic
    • consider limiting visitors and screening visitors similar to staff screenings
  • If you provide transit services, reduce the number of individuals transported to implement social distancing
  • Consider cancelling non-essential services and activities. For essential services and meetings, provide them in large, well-ventilated space with 6 feet distance between participants; consider what meetings can be held remotely using technology
  • Know the health care providers/public health officials in your community to refer symptomatic individuals to and take care to follow their protocol to access screening;
  • Cooperate with local public health officials when they contact you for information relating to contact tracing;
  • Contact your local public health department and discuss your policies and intentions should COVID-19 become widespread and request their input; and
  • Continue to monitor the recommendations and guidance available from CDC, and state and local public health officials.

3. Can shelters and agencies screen clients, staff and others for symptoms?

Yes, we think it is prudent to implement screening protocols, especially for shelters, transitional housing providers, and providers of health care services. These include screening every individual for respiratory symptoms, taking their temperatures, and gathering information about recent travel history or COVID-19 exposure. It would also be reasonable to limit visitors and non-essential personnel. Even before widespread community transmission, it would be reasonable to consider screening visitors for recent travel history and potential symptoms or limit the number of visitors. 

We also believe it is prudent to implement similar screening procedures for staff and volunteers. If community transmission is widespread, you may want to restrict volunteers if you can continue to provide essential services without them. 


4. What will happen if a client tests positive for COVID-19?

If your local public health officials are still doing contact tracing, it is likely the shelter, housing provider, or agency would be notified and public health officials may request information on other individuals who were exposed to this person. Assuming the client is experiencing only mild symptoms, it is very likely they may remain in the community. Shelters, housing providers, and agencies should work with their local public health departments on whether and how these individuals will self-quarantine. We understand different cities are exploring various options for quarantine such as renting local hotels and temporary mobile housing. According to CDC guidance, local public health officials would evaluate the client’s living situation and determine whether the setting would be appropriate. 

Depending on the severity of the outbreak, there may not be other options than remaining in the shelter or transitional housing especially if the client has mild symptoms. Because this situation is likely to arise if there is widespread community transmission, we recommend you have an action plan for this scenario, including:

  • Reviewing the CDC guidance for Homeless Shelters;
  • Reviewing the CDC guidance for Implementing Home Care for People Not Requiring Hospitalization for COVID-19;
  • Working with your local public health officials to determine an appropriate plan; and
  • Assessing any additional staffing needs this situation would present and potential staffing challenges, such as how to protect staff members from exposure.

Our Coronavirus Resources webpage offers additional information for long-term care facilities, hospitals, and other businesses.

Davis Brown Law Firm blogs, legal updates, and other content are for educational and informational purposes only. This is not legal advice and it does not create an attorney/client relationship between Davis Brown and readers. Each circumstance is different; readers should consult an attorney to understand how this content relates to their personal situation. You should not use Davis Brown blogs or content as a substitute for legal advice from a licensed attorney in your state. Reproduction of Davis Brown content without written consent is prohibited.