On February 10, 2021, the Centers for Disease Control and Prevention (“CDC”) provided updated quarantine recommendations for vaccinated persons.   Those who are fully vaccinated and meet certain other criteria may no longer be required to quarantine following an exposure to someone with COVID-19. Additional considerations are provided for patients and residents in healthcare settings.

CDC Recommendation for Vaccinated Persons

Due to the limited information available on how much the vaccines might reduce transmission of COVID-19, or how long the protection lasts, or the efficacy of the vaccines against various strains of the disease, the CDC recommends that vaccinated persons should continue to follow current guidance to protect themselves and others by wearing a mask, staying at least 6 feet away from others, avoiding crowds and poorly ventilated areas, covering coughs and sneezes, and washing hands frequently. The CDC further recommends that vaccinated persons follow the CDC travel guidance, and applicable workplace or school guidance concerning the use of personal protective equipment and testing for COVID-19.

However, the CDC recommends that vaccinated persons exposed to someone with confirmed or suspected COVID-19 will not be required to quarantine if they meet all of the following criteria:

  • They are fully vaccinated (with at least 2 weeks since their final dose);
  • They are within 3 months of receipt of their last dose;
  • They have remained asymptomatic since the current COVID-19 exposure.

Those who have been vaccinated but do not meet the above criteria should continue to follow the current guidance on quarantine after an exposure to COVID-19.

Fully vaccinated persons who meet the above criteria and do not need to quarantine should still watch for symptoms of COVID-19 for 14 days following an exposure. If they experience symptoms, they should be evaluated for COVID-19.

Vaccinated Healthcare Personnel, Patients and Residents in Healthcare Settings

The above criteria should also be applied to exposed healthcare personnel who are fully vaccinated, as a strategy to alleviate staffing shortages.

However, the CDC recommends that vaccinated inpatients and residents in healthcare settings should continue to quarantine following an exposure to COVID-19, even if they have been fully vaccinated and otherwise meet the above criteria. Outpatients should be cared for using appropriate transmission-based precautions. This exception is based on the unknown effectiveness of the vaccine on this population, the higher risk of severe disease and death, and challenges with social distancing in healthcare settings. Healthcare facilities can, however, consider waiving quarantine requirements for vaccinated patients and residents, in consultation with public health officials, in order to mitigate critical issues, such as lack of space, staff and PPE.

The CDC expects to update the quarantine recommendations for vaccinated persons, including the timing since receipt of the last dose, when more data becomes available and additional COVID-19 vaccines are authorized.

Takeaway for Employers

Persons who are fully vaccinated and meet the CDC criteria must still comply with their state quarantine requirements and their employer’s requirements before returning to work. New York has not yet adopted the CDC’s updated recommendation.

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These recommendations apply only with regard to the currently authorized vaccine products in the United States, the Pfizer-BioNTech and Moderna COVID-19 vaccines.

 

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Putney, Twombly, Hall & Hirson LLP

 

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