Throughout the COVID-19 pandemic, the U.S. Centers for Disease Control and Prevention (CDC) has been one of the primary resources providing the public with recommendations on all aspects of the virus, and it has closely monitored the evolving science for information that would warrant reconsideration of its recommendations. As a result of those ongoing efforts, on December 2, 2020, the CDC announced updated COVID-19 quarantine guidelines intended to reduce the burden of and potentially increase community compliance with post-exposure quarantine recommendations. The revised guidelines offer alternatives to the prior 14-day quarantine recommendation for individuals coming into close contact with positive or presumed-positive individuals, and include both 10-day and 7-day quarantine options under certain circumstances.
In general, local public health authorities ultimately determine and establish the quarantine options for their respective jurisdictions, but to date the CDC has consistently recommended a quarantine period of a full 14 days. However, based on local circumstances and resources, the CDC now has determined that the following shorter quarantine periods are acceptable alternatives:
- 10-Day Quarantine: quarantine can end after Day 10 without testing, provided no symptoms have been reported during daily monitoring.
- 7-Day Quarantine: when diagnostic testing resources are sufficient and available, quarantine can end after Day 7 with a negative test taken within 48 hours of the final day of quarantine (i.e., at least five days following close contact).
According to the CDC, these recommendations for quarantine options of less than 14 days balance a reduced burden against a small but non-zero risk of post-quarantine infection that is informed by new and emerging science. For both alternatives, the CDC advises that mitigation strategies, including “correct and consistent mask use, social distancing, hand and cough hygiene, environmental cleaning and disinfection, avoidance of crowds, and adequate indoor ventilation,” along with daily self-monitoring for symptoms should continue through Day 14 following close contact. In addition, the CDC explains that testing for the purpose of earlier discontinuation of quarantine should occur only if it will have no impact on community diagnostic testing, and testing of individuals seeking evaluation for infection should be prioritized. It is important to note that under the new guidance, individuals are free to continue quarantining for the full 14 days without testing per existing recommendations. In fact, the CDC indicates that this option “maximally reduces risk of post-quarantine transmission risk and is the strategy with the greatest collective experience at present.”
This revised quarantine guidance from the CDC comes a little over a month after the agency changed and expanded its definition of “close contact,” which health departments rely upon to conduct contact tracing. As of October 21, 2020, the CDC now defines a close contact as someone who was within six feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period (whether or not wearing a face covering or other PPE) starting from two days before illness onset (or, for asymptomatic patients, two days prior to test specimen collection) until the time the patient is isolated. Thus, individual exposures added together over a 24-hour period (i.e., three five-minute exposures for a total of 15 minutes) amount to a “close contact” under the CDC’s revised definition. The CDC previously had defined “close contact” as spending at least 15 consecutive minutes within six feet of an infected individual. Examples of close contact also include kissing or hugging, sharing eating or drinking utensils, talking within three feet, and direct touching. Close contact generally does not include brief interactions, such as walking past a person.
In light of these developments, employers should make certain they are using the most up-to-date definition of “close contact” when determining whether an employee is required to quarantine before returning to work following a potential COVID-19 exposure. In addition, employers should review their current pandemic response and return-to-work policies to determine whether to continue requiring employees to quarantine for 14 days, or to revise their policies to incorporate the 10-day and/or 7-day quarantine periods following close contact. Because the CDC maintains that the 14-day quarantine period is the optimal way to reduce risk, employers may decide that the safest option for their workforce is to leave the 14-day quarantine period in place. However, for employers that have specific staffing or business needs, it may be advantageous to tailor their policies to include the 10-day and 7-day quarantine alternatives, assuming that diagnostic testing resources are sufficient and available in their communities.