Update from 06.07.2020

Governor Cuomo announced revisions to the statewide guidelines for Religious and Funeral Services that permits these services to be conducted with 25% occupancy during phase two of reopening so long all social distancing protocols are in place. The revised guidelines are posted on the NY Forward website. (https://forward.ny.gov/statewide-guidelines).

The seven regions that have already entered phase two - Capital Region, Central New York, Finger Lakes, Mohawk Valley, North Country, Southern Tier and Western New York - can begin offering services at 25% occupancy beginning today, June 7th. For those in regions in phase 1, the original guidelines of 10 attendees still applies. We have inquired as to whether the 25% occupancy limit means 25% at a time akin to the 10 person limit. We anticipate this clarification as well as answers to our other questions shortly and will provide an update as soon as those details are available.

The Governor also signed an executive order giving you the discretion to require individuals to undergo temperature checks prior to being allowed admittance into the funeral home. You now have the discretion to deny admittance to (i) any individual who refuses to undergo such a temperature check and (ii) any individual whose temperature is above that proscribed by New York State Department of Health Guidelines. This is in addition to the previously issued executive order allowing you to require face coverings for entrance into the funeral home.

We also sought clarification on a few points contained in the guidelines. Below is the written clarification we obtained from the Governor’s counsel.

  1. The guidelines state to limit the attendee capacity to 10 people for any funeral service occurring indoors during phase 1 of reopening. This is 10 people in the building at a time in addition to the immediate family.
  2. The guidelines say to limit passengers in vehicles to 50% of max occupancy if all are wearing masks. An exception to this rule is when the funeral home provides livery service and only individuals from the same household are in the vehicle. In that case you can go up to the vehicle’s maximum capacity.
  3. The guidelines say that during phase 1 of reopening you can have multiple gatherings of 10 people if you have separate buildings with entrances and exits that ensure people do not interact/commingle. We asked if it was permissible to use multiple chapels in the same building simultaneously if the funeral home has the ability to have people enter and exit the building through separate doorways such that people will not interact/commingle. This is not permissible. Under phase 1 it has to be separate buildings. In order to prevent any kind of creative interpretation of this rule the Governor’s office has strictly interpreted this as meaning 10 persons per building for both religious and funeral services.

as of 05.26.2020

Following the State's Interim Guidance, here are some highlights:

  • The guidance applies to ALL religious and funeral gatherings, including burial and committal services until rescinded or amended by the State.
  • You must ensure that for any funeral service occurring indoors, the attendee capacity is limited to 10 people.
    • If separate buildings are available for use, you may have multiple groups of 10 in separate buildings at the same time, so long as the buildings have separate entrances and exits designated and groups do not interact.
  • You must ensure that a distance of at least six feet is maintained among all individuals at all times, unless safety of the core activity requires a shorter distance (e.g. pallbearing) or the individuals are members of the same household.
  • You must prohibit the use of tightly confined spaces (e.g. vehicles, elevators) by more than one individual at a time, unless all individuals in such space at the same time are wearing acceptable face coverings. However, even with face coverings in use, occupancy must never exceed 50% of the maximum capacity of the space or vehicle, unless it is designed for use by a single occupant.
  • Reducing interpersonal contact and congregation through such methods as:
    • Allowing drive-in services:
      • Ensure attendees remain in the vehicle in which they arrived.
      • Attendees should not interact physically with clergy, employees, or attendees in other vehicles.
      • Vehicles should contain only members of a single household.
      • Cars must be at least 6 feet apart or use alternate parking spaces.
    • Offering multiple service times, including separate times for vulnerable populations (e.g. those over 70, who have underlying health condition, or those who are immunocompromised).
    • Encouraging advanced sign-ups to manage capacity.
      • You must prohibit touching, hugging, or kissing the body of a deceased person who had confirmed or suspected COVID-19 per CDC guidance, “Funeral Guidance for Individuals and Families.”
      • You must prohibit shared food and beverages (e.g. buffet style meals).

Please note, per the state, these guidelines are based on the best-known public health practices at the time of publication and the documentation upon which these guidelines are based can and does change frequently. Again, you are accountable for staying current with any updates to these requirements, as well as incorporating them into any funeral services and/or Safety Plan.

NYSFDA will continue to monitor updates and guidelines and share new information with you as soon as it's available. If you have any questions specific to reopening in your region, you can email your Regional Control Room (click here for email addresses) or contact NYSFDA at info@nysfda.org.

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