-Rules based on hard numeric standards serve as a disincentive for high-frequency surveillance testing programs.

-Schools that test only symptomatic individuals will naturally report many fewer positive cases than those with strong surveillance testing plans because age-based data shows younger populations have a higher incidence of asymptomatic cases.

-Comprehensive surveillance testing and contact tracing will identify asymptomatic cases. This can only lead to beneficial public health outcomes for schools and surrounding communities. 

-It is in the public health interest of the state of New York to incentivize schools to develop and conduct comprehensive surveillance testing plans where all students and faculty are tested frequently, not to penalize those who do with shutdowns at, in some cases, very low per-capita rates of infection. 

-In the same way a one-number-fits-all rule would not be right for the cities of New York, it is not right for post-secondary education communities of vastly different sizes with vastly different testing protocols. 

-Therefore, we ask that schools with comprehensive covid-19 surveillance testing programs (e.g. Cornell University) be required to go online when a 1% threshold of the college community (students + faculty and staff) tests positive, or 250 positives cases are detected in 2 weeks (whichever is less) and that the NYS covid-19 orders are amended accordingly.