On December 27, 2021, the Centers for Disease Control and Prevention (CDC) announced an update to its isolation and quarantine guidance. Although the CDC’s update shortens both the isolation and quarantine periods, as described more fully below, the changes largely affect only asymptomatic individuals. Moreover, because local guidance may differ from the CDC’s recommendations, employers should keep in mind all applicable state and local requirements when deciding whether to amend their own rules.
Isolation
An individual should isolate when they have tested positive for COVID-19 or are experiencing symptoms of the virus. The CDC now recommends that individuals who test positive for COVID-19 remain home for 5 days, regardless of vaccination status. If the individual is asymptomatic, or symptoms are resolving after those 5 days, the individual may leave isolation. The individual, however, should continue to wear a mask when around others for 5 additional days.
Quarantine
An individual should quarantine when they have been in “close contact” with someone who has COVID-19, which means being within 6 feet of that individual for a cumulative total of 15 minutes or more over a 24-hour period. The CDC’s revised quarantine recommendations largely depend on an individual’s vaccination status.
Specifically:
- The following individuals do not need to quarantine if they are asymptomatic; rather, they should wear a mask around others for 10 days and test on day 5, if possible:
- Those who have received a COVID-19 booster;
- Those who have received their Pfizer or Moderna COVID-19 vaccinations within the last 6 months; and
- Those who have received the Johnson & Johnson (J&J) vaccine within the last 2 months.
- The following individuals should (i) stay home for 5 days, after which they should continue to wear a mask around others for an additional 5 days; or (ii) if the individual cannot quarantine, they should wear a mask for a full 10 days. Either way, they should test on day 5 if possible.
- Those who are unvaccinated;
- Those who have completed their Pfizer or Moderna COVID-19 vaccine series more than 6 months ago and are not boosted; and
- Those who have completed their J&J vaccine more than 2 months ago and are not boosted.
The CDC recommends that anyone who develops symptoms get tested and stay at home. The CDC, however, does not require an individual to produce a negative test in order to end isolation or quarantine.
What the Changes Mean
Many states are beginning to revise their recommendations in light of the CDC’s changes, but employers should continue to monitor their local jurisdictions’ guidelines as well when deciding whether and when to change rules regarding quarantine periods. Further, The CDC’s new recommendations may be a signal that the agency is planning to modify the definition of “fully vaccinated” to include COVID-19 booster injections, since its present guidance turns on individuals’ booster status.
We will continue to monitor and advise on local developments around quarantine and isolation.
*Kamil Gajda, Law Clerk – Admission Pending (not admitted to the practice of law) in the firm’s New York office, contributed to the preparation of this post.
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