Client Alert 
December 29, 2021
UPDATED January 10, 2022

CDC Updates COVID-19 Quarantine Guidelines
The Centers for Disease Control and Prevention (CDC) issued new guidance updating the isolation and quarantine period for all individuals, regardless of vaccination status, both after testing positive for COVID-19 and after being in close contact with someone who tested positive for COVID-19 (“CDC Revised Quarantine Guidance”). The previous standards and new rules are set out below.

As always, employers may impose more restrictive standards and exclude employees from the workplace for longer periods of time and/or require employees to use additional safety measures.

Quarantine After Testing Positive

The CDC Revised Quarantine Guidance provides for a shortened quarantine period for all individuals who test positive for COVID-19, regardless of vaccination status:
Old Rule

Individuals who test positive for COVID-19, regardless of vaccination status must:
  • Quarantine for 10 days, and
  • Quarantine until at least 24 hours have passed since their recovery (meaning, no longer having a fever without the use of fever-reducing medications and other symptoms are improving).
New Rule

Individuals who test positive for COVID-19, regardless of vaccination status must:
  • Quarantine for 5 days. The day symptoms start, or if asymptomatic, the date the test was taken, is day 0.
  • If the individual has no symptoms or their symptoms are resolving, they can exit quarantine after 5 days.
  • Continue to wear a mask while around others for 5 additional days after they exit quarantine.
Even under this new rule, if the individual continues to have fever or their other symptoms have not improved after 5 days of isolation, they should wait to end their isolation until they have been fever-free for 24 hours without the use of fever-reducing medication and other symptoms have improved (other than loss of taste/smell and fatigue, which can persist).

Notably, the CDC does not require a negative test to come out of quarantine after testing positive. Rather, if the individual has access to a COVID-19 test and "wants" to take a test, and has been fever-free for 24 hours without the use of fever reducing medication with other symptoms also improving, they are encouraged to take an antigen (i.e., rapid) test around the 5th day of quarantine, and are instructed to continue quarantining until 10 day if the result is positive.
 
Quarantine After Exposure to COVID-19
  
The CDC Revised Quarantine Guidance provides for a shortened quarantine period for all asymptomatic individuals, regardless of vaccination status. However, the length of time for which an individual will need to comply with additional safety measures will depend on whether they are vaccinated and/or boosted, and how long ago they were vaccinated:
Old Rule - Fully Vaccinated
 
Individuals who have been exposed to COVID-19 but are not experiencing COVID-19 symptoms and are fully vaccinated do not need to quarantine, but should:
  • Wear a mask around others for 14 days, and
  • Get tested 5-7 days after close contact.
New Rule - Fully Vaccinated and Boosted (If Eligible) or Positive COVID-19 Test in Last 90 Days
 
Individuals who have been exposed to COVID-19 but are not experiencing COVID-19 symptoms and are up to date on their COVID-19 vaccines (meaning they (a) have completed the primary series of Pfizer or Moderna or received the J&J vaccine and have been boosted if eligible, (b) have completed the primary series of the Pfizer or Moderna vaccine within the last 5 months, or (c) received the J&J vaccine within the last 2 months) do not need to quarantine, but should:
  • Wear a mask around others for 10 days, and
  • Get tested on day 5, if possible.
Old Rule - Not Fully Vaccinated

Individuals who have been exposed to COVID-19 but are not experiencing COVID-19 symptoms and are not fully vaccinated must quarantine for 10 days or otherwise “test out” after 7 days. To “test out,” the individual would need to (a) quarantine for at least 7 days, and (b) obtain a COVID-19 test any time after the 5th day of quarantine. If the test came back negative, the employee could exit quarantine after the 7th day of quarantine.
New Rule - Not Fully Vaccinated or Eligible For But Have Not Gotten a Booster Dose

Individuals who have been exposed to COVID-19 but are not experiencing COVID-19 symptoms and who (a) are unvaccinated, (b) have completed the primary series of Pfizer or Moderna over 5 months ago and are not boosted, or (c) completed the primary series of J&J vaccine over 2 months ago and are not boosted, should:
  • Quarantine for 5 days and after that, continue to wear a mask around others for 5 additional days after they exit quarantine (or, if they cannot quarantine, wear a mask for 10 days after close contact both at home and in public), and
  • Get tested on day 5, if possible.
Note that the CDC has also eliminated any distinction between unvaccinated individuals and those that were vaccinated but “too long” ago and have not been boosted with respect to quarantining after COVID-19 exposure.

In any instance, if an individual begins experiencing symptoms, they should immediately quarantine until a negative test result confirms symptoms are not attributable to COVID-19.

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If you have questions or would like additional information, please contact our Labor & Employment attorneys or the primary EGS attorney with whom you work.

This memorandum is published solely for the informational interest of friends and clients of Ellenoff Grossman & Schole LLP and should in no way be relied upon or construed as legal advice.