Airport Alert: U.S. Government Releases Updated Runway to Recovery Guidance and FAA Policy on Revenue Use for Health Screening Programs
December 21, 2020
Today a U.S. Government interagency group released, 'Runway to Recovery: The United States Framework for Airlines and Airports to Mitigate the Public Health Risks of Coronavirus' (Version 1.1), an updated guidance document developed jointly by the U.S. Departments of Transportation (DOT), Homeland Security (DHS), and Health and Human Services (HHS). The document, originally released in July, includes the U.S. Government's new and updated guidance to airports and airlines for implementing measures to mitigate the spread of COVID-19 during air travel. The revised document specifically recognizes the value of COVID-19 testing programs for reducing the spread of COVID-19 and provides a recommended framework for implementing a testing program as part of a broader, multi-layered strategy.
In addition, this evening the Federal Aviation Administration (FAA) released an update to its existing guidance to permit airports to use their revenue to cover the costs of health screening programs or activities, including COVID-19 testing programs, under certain conditions. This is a shift from FAA's current policy where the agency indicated that the use of revenue for public health screenings is generally not permitted. As AAAE had requested in its comments to FAA earlier this month, FAA emphasized that airports may voluntarily choose to undertake health screenings in order to jump start a recovery, but such programs are not mandatory.
Collectively, the updates released today from the U.S. Government interagency group and FAA are part of a broader effort of the federal government, working with industry and international authorities, to provide airports with a framework for health screening programs and to promote a recovery in air travel.
U.S. Government's Runway to Recovery Guidance (Version 1.1)
Runway to Recovery Background. In July, DOT, DHS, and HHS issued the Runway to Recovery guidance document which included recommendations to airports and airlines for implementing 11 specific measures to mitigate the public health risks associated with COVID-19, prepare for increased travel volume, introduce more consistency throughout the system, and ensure that aviation safety and security are not compromised. These measures focused on face coverings, social distancing, enhanced cleaning and disinfection procedures, contact tracing, minimizing touch points and shared surfaces, among other things.
FAA and the U.S. Government have maintained that Runway to Recovery guidance is a living document and have engaged with airports and airlines to assess what additional mitigation measures or recommendations may be necessary. AAAE's July 2 Airport Alert provides a comprehensive overview of the original Runway to Recovery document.
New Recommendations on COVID-19 Testing. Since the fall, an increasing number of airports have deployed COVID-19 testing and screening programs for passengers. In the updated document, the U.S. Government recognizes that COVID-19 testing before and after travel, if used in combination with other mitigation measures, can reduce the spread of COVID-19 during air travel and potentially reduce or eliminate travel restrictions and/or quarantine requirements at the passenger's destination. In addition, the document provides the following detailed recommendations for airports that are considering the deployment of a COVID-19 testing program:
FAA's Updated Guidance on Use of Revenue for Health Screening Programs
As airports are aware, federally obligated airports may only use revenue for the capital or operating costs of the airport. Under its policy outlined in a May 29 document, FAA indicated that costs associated with certain types of public health activities may be considered legitimate for purposes of airport grant assurances, including testing and health screening of airport employees. However, FAA advised that the use of airport employees for public health screenings is generally not considered a proper use of revenue.
In November, FAA proposed to update its existing guidance to permit airports to use their revenue to cover the costs of health screening programs or activities, including COVID-19 testing programs, under certain conditions. In response, AAAE submitted comments to FAA, emphasizing that many AAAE members support the general proposition of allowing revenue to be used for public health screening programs. However, AAAE also expressed members' concerns over the process by which FAA is proposing to update the policy and the proposed limitations that would be imposed on airports.
New Guidance on Revenue Use for Screenings. FAA's guidance, 'Information for Airport Sponsors Considering COVID-19 Restrictions or Accommodations,' now permits revenue to be used for airport health screening programs or activities with some limitations:
The updated policy is largely similar to the proposal that FAA circulated in November. However, one notable change is that FAA removed the requirement for health screening programs to be limited to outgoing passengers only.
Airport Consequence Management Plans. In the updated guidance and similar to the Runway to Recovery document, FAA indicates that airports developing a health screening program should create a 'consequence management plan' that describes the actions to be taken in the event a person tests positive for COVID-19.
It is critical that airports sponsors have a written consequence management plan to identify actions to be taken related to any COVID-19 screening measure that identifies a person believed to be infected with the SARS-CoV-2 virus. Airports should work with their airlines, the testing provider, and local public health authorities to coordinate a consequence management plan on how to handle passengers with positive test results (and their close contact travel companions) to minimize risk to other passengers and personnel at the airport. Example elements of this plan include coordination with the airlines on denial of boarding procedures, isolation and removal of the test-positive passenger and travel companions from the airport, referral to the appropriate local health authorities for further diagnosis and isolation requirements, and a communication plan for passengers prior to arrival at the airport. In this communication plan, passengers should be informed of any testing requirements and consequences of a positive test result well before they arrive at the airport. Coordination with airlines, TSA, CBP, airport law enforcement, local public health authorities, and other entities should also be conducted in developing a health screening program.
FAA also clarified in the guidance that airport revenue may be used for purposes of 'consequence management' of people with symptoms or who test positive.
If you have any questions or comments regarding the updated guidance, please contact Justin Barkowski at justin.barkowski@aaae.org.
Today a U.S. Government interagency group released, 'Runway to Recovery: The United States Framework for Airlines and Airports to Mitigate the Public Health Risks of Coronavirus' (Version 1.1), an updated guidance document developed jointly by the U.S. Departments of Transportation (DOT), Homeland Security (DHS), and Health and Human Services (HHS). The document, originally released in July, includes the U.S. Government's new and updated guidance to airports and airlines for implementing measures to mitigate the spread of COVID-19 during air travel. The revised document specifically recognizes the value of COVID-19 testing programs for reducing the spread of COVID-19 and provides a recommended framework for implementing a testing program as part of a broader, multi-layered strategy.
In addition, this evening the Federal Aviation Administration (FAA) released an update to its existing guidance to permit airports to use their revenue to cover the costs of health screening programs or activities, including COVID-19 testing programs, under certain conditions. This is a shift from FAA's current policy where the agency indicated that the use of revenue for public health screenings is generally not permitted. As AAAE had requested in its comments to FAA earlier this month, FAA emphasized that airports may voluntarily choose to undertake health screenings in order to jump start a recovery, but such programs are not mandatory.
Collectively, the updates released today from the U.S. Government interagency group and FAA are part of a broader effort of the federal government, working with industry and international authorities, to provide airports with a framework for health screening programs and to promote a recovery in air travel.
U.S. Government's Runway to Recovery Guidance (Version 1.1)
Runway to Recovery Background. In July, DOT, DHS, and HHS issued the Runway to Recovery guidance document which included recommendations to airports and airlines for implementing 11 specific measures to mitigate the public health risks associated with COVID-19, prepare for increased travel volume, introduce more consistency throughout the system, and ensure that aviation safety and security are not compromised. These measures focused on face coverings, social distancing, enhanced cleaning and disinfection procedures, contact tracing, minimizing touch points and shared surfaces, among other things.
FAA and the U.S. Government have maintained that Runway to Recovery guidance is a living document and have engaged with airports and airlines to assess what additional mitigation measures or recommendations may be necessary. AAAE's July 2 Airport Alert provides a comprehensive overview of the original Runway to Recovery document.
New Recommendations on COVID-19 Testing. Since the fall, an increasing number of airports have deployed COVID-19 testing and screening programs for passengers. In the updated document, the U.S. Government recognizes that COVID-19 testing before and after travel, if used in combination with other mitigation measures, can reduce the spread of COVID-19 during air travel and potentially reduce or eliminate travel restrictions and/or quarantine requirements at the passenger's destination. In addition, the document provides the following detailed recommendations for airports that are considering the deployment of a COVID-19 testing program:
- Dual-Test Approach. A 'dual test approach,' which includes one pre-departure test and a second post-arrival test, would be most effective in reducing the risk of COVID-19 spread. A pre-departure test should occur one to three days prior to departure, and any passengers testing positive or having pending results should not be permitted to travel. A post-arrival test should occur three to five days after arrival in combination with monitoring symptoms and staying home for seven days.
- Testing Locations. Testing one to three days before initiating travel, with results available prior to arriving at the airport, is preferable than testing at the airport because it would reduce the risk of in-airport exposures. This would make it simpler to manage positive-testing passengers and any rebooking of itineraries. However, the document acknowledges that testing onsite at an airport may be necessary in certain cases, such as transiting passengers with broken travel itineraries.
- Protocols to Manage Passengers Testing Positive. COVID-19 testing facilities at airports should have plans for preventing the travel of persons who receive a positive result and their travel companions until the local public health authority can review and provide clearance for travel. Passengers who test positive at the airport should be isolated as soon as feasible and denied boarding.
- Reporting Mechanism for Positive Tests. COVID-19 testing facilities at airports should establish a reporting mechanism to allow for immediate reporting of persons who test positive to the local health authority, the quarantine station with jurisdiction for the airport, the airport, and airlines in a timeframe that enables swift travel restriction when needed.
- Qualified Testing Professionals. Testing should be performed by individuals who are trained to perform the test at sites approved by appropriate public health authorities.
- Education of Passengers. Passengers should be informed and educated on any testing requirements and consequences of a positive test results well before they arrive at the departure and arrival airports.
FAA's Updated Guidance on Use of Revenue for Health Screening Programs
As airports are aware, federally obligated airports may only use revenue for the capital or operating costs of the airport. Under its policy outlined in a May 29 document, FAA indicated that costs associated with certain types of public health activities may be considered legitimate for purposes of airport grant assurances, including testing and health screening of airport employees. However, FAA advised that the use of airport employees for public health screenings is generally not considered a proper use of revenue.
In November, FAA proposed to update its existing guidance to permit airports to use their revenue to cover the costs of health screening programs or activities, including COVID-19 testing programs, under certain conditions. In response, AAAE submitted comments to FAA, emphasizing that many AAAE members support the general proposition of allowing revenue to be used for public health screening programs. However, AAAE also expressed members' concerns over the process by which FAA is proposing to update the policy and the proposed limitations that would be imposed on airports.
New Guidance on Revenue Use for Screenings. FAA's guidance, 'Information for Airport Sponsors Considering COVID-19 Restrictions or Accommodations,' now permits revenue to be used for airport health screening programs or activities with some limitations:
- During the COVID-19 public health emergency, airports may use airport revenue to cover the costs of health screening activities for passengers and people entering sterile areas. This use of airport revenue is acceptable as long as:
1) The health screening program is approved by Federal, State, or local public health departments;
2) The health screening activities are conducted by certified health professionals and not airport staff;
3) The airport has consulted with the airlines and other tenants in accordance with their lease agreements about the proposed health screening program. This consultation should include, at a minimum, notice of the elements and cost of the proposed program, a reasonable period of time to provide comment, and some means by which to record comments and conclusions in regard to the proposed program for consideration by the airport sponsor; and
4) The sponsor regularly evaluates the program for effectiveness and to ensure it meets Federal and State health guidelines.
The updated policy is largely similar to the proposal that FAA circulated in November. However, one notable change is that FAA removed the requirement for health screening programs to be limited to outgoing passengers only.
Airport Consequence Management Plans. In the updated guidance and similar to the Runway to Recovery document, FAA indicates that airports developing a health screening program should create a 'consequence management plan' that describes the actions to be taken in the event a person tests positive for COVID-19.
It is critical that airports sponsors have a written consequence management plan to identify actions to be taken related to any COVID-19 screening measure that identifies a person believed to be infected with the SARS-CoV-2 virus. Airports should work with their airlines, the testing provider, and local public health authorities to coordinate a consequence management plan on how to handle passengers with positive test results (and their close contact travel companions) to minimize risk to other passengers and personnel at the airport. Example elements of this plan include coordination with the airlines on denial of boarding procedures, isolation and removal of the test-positive passenger and travel companions from the airport, referral to the appropriate local health authorities for further diagnosis and isolation requirements, and a communication plan for passengers prior to arrival at the airport. In this communication plan, passengers should be informed of any testing requirements and consequences of a positive test result well before they arrive at the airport. Coordination with airlines, TSA, CBP, airport law enforcement, local public health authorities, and other entities should also be conducted in developing a health screening program.
FAA also clarified in the guidance that airport revenue may be used for purposes of 'consequence management' of people with symptoms or who test positive.
If you have any questions or comments regarding the updated guidance, please contact Justin Barkowski at justin.barkowski@aaae.org.
