On iOS 13.7+ you can now side-load your EN Server configuration before submitting to Apple.
(Source document, Apple Documentation)
This will allow you to retrieve and submit exposure keys to a Key Server on your local device.
Generating a Config File
Starting with the sample test configuration.
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Install profile that enables Developer -> Exposure Notification
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Transfer the ExposureNotification-DeveloperSettings listed above to your phone. If you click on a profile in an email, message, or the Files app, you will get a message asking you to chose a location to install it, and a message that you have to go to settings to install it.
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