CDC Updates COVID-19 Guidance on Testing, Quarantine, and Release from Isolation

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In the past several weeks, the Centers for Disease Control and Prevention revised its guidance on several significant issues of interest to employers –whether testing is required following exposure to COVID-19, when to quarantine, and when to stop home isolation.

COVID-19 Testing Overview. Somewhat controversially, the CDC states that not everyone needs to be tested. Testing is recommended for: those with symptoms of COVID-19; those who have been in close contact (within 6 feet of an infected person for at least 15 minutes); and those who have been asked or referred for testing by their healthcare provider, or local/state health department. Individuals should home-isolate pending their test results.

Notably, for healthcare workers, the CDC does not recommend testing for close contact, unless the worker has symptoms, is a vulnerable individual, or their healthcare provider or state/local health department recommends such testing.

It is worth noting that the Equal Employment Opportunity Commission’s COVID-19 guidance permits employers to broadly require testing before allowing employees to enter the workplace. In addition, the CDC’s retreat from broad testing recommendations has come under fire from many health officials and scientists.

When to Quarantine. Of significance, the CDC suggests that there may be immunity for up to three months following infection with COVID-19. Specifically, the CDC states that those who have had COVID-19 do not need to quarantine or get tested again following close contact with an infected individual for a period of three months, unless they have symptoms. Otherwise, those in close contact should stay at home for 14 days from their last contact with the infected individual and self-monitor for symptoms. Moreover, the CDC expressly states that individuals should quarantine even if they test negative, as symptoms may appear up to 14 days after exposure.

The CDC also expands the definition of “close contact.” In addition to its previous definition of being within 6 feet of an infected individual for 15 minutes or more (which is repeated in the CDC’s other guidance), the CDC lists the following:

  • Providing care at home to an infected individual
  • Having direct physical contact (e.g. hugging or kissing) with an infected individual
  • Sharing eating or drinking utensils with an infected individual
  • An infected individual sneezed, coughed or somehow got respiratory droplets on the person

The CDC further provides various quarantine scenarios:

  • Those who had close contact with no further contact should quarantine for 14 days from the date of contact.
  • Those who had close contact and live with an infected individual, but can avoid further close contact should quarantine for 14 days from the date the household member began home isolation.
  • Those under quarantine who had close contact with either the same or a different infected individual (such as another household member who becomes sick) must restart their 14-day quarantine period from the date of their most recent close contact.
  • Those who cannot avoid close contact with an infected household member must avoid outside contact while the household member is sick and then quarantine for 14 days after the household member meets the criteria for ending home isolation.

Notably, despite the CDC’s apparent recognition of limited immunity following infection, it has not updated its Interim Guidelines for COVID-19 Antibody Testing to reflect this changed position. Thus, as of August 28, the Interim Guidelines still specify that antibody test results should not be used to make decisions about returning persons to the workplace.

Travel During the COVID-19 Pandemic. The CDC reiterates its recommendation to avoid travel. However, it has retreated from its recommendation to quarantine for 14 days following out-of-state or foreign travel. Now the CDC offers the following recommendations after any travel: stay at least 6 feet away from non-household members, whether inside or outside; wear a mask; wash or sanitize hands frequently; and monitor for symptoms.

If the travel is “higher-risk,” meaning to an area with high levels of COVID-19, the CDC then makes the following recommendations: “stay home as much as possible” (although not specifically for 14 days); avoid those at increased risk for severe illness from COVID-19: and consider getting tested.

When You Can Be Around Others After You Had or Likely Had COVID-19. The CDC reiterates its suggestion of three-month immunity in this guidance as well. Specifically, the CDC states that those having close contact with someone with COVID-19 should isolate for 14 days following exposure unless they had COVID-19 within the last three months, have recovered, and do not have symptoms.

The CDC also sets forth guidelines for various other scenarios, as follows:

  • Those who had or likely had COVID-19 with symptoms may be around others if 10 days have passed since the symptoms first appeared, they have been fever-free without fever-reducing medications for at least 24 hours, and their other symptoms have improved.
  • Those who tested positive for COVID-19 without symptoms may be around others once 10 days have passed since the positive test, as long as they remain asymptomatic.
  • Those who were severely ill with COVID-19 may need to stay home for up to 20 days, and may need to be tested before being released from home isolation, depending on what their healthcare provider determines.
  • Those with COVID-19 and compromised immune systems may need to be tested before being released from home isolation, depending on what their healthcare provider determines.

Notably, the CDC no longer recommends testing for most people to determine whether they may be released from home isolation, except as to those who are severely ill or immunocompromised or who have been so directed by their healthcare provider.