Updated CDC Guidance on Quarantine Duration

Posted by Attorney David McClurg in Employer-Employee Relationship, Labor Relations, COVID-19 / Comments

On December 2, 2020, the Centers for Disease Control and Prevention (CDC) revised its guidance on the recommended length of quarantine for individuals who are asymptomatic, but have had “close contact” with someone who has tested positive for COVID-19. (Note that the CDC has recently redefined “close contact” to include exposure within 6 feet of an infected person for a cumulative – not single – total of 15 minutes or more within a 24-hour period.) 

The revised guidance, while still recommending a 14-day quarantine period, now permits exposed individuals to end quarantine after 7 days with a negative test (collected within 48 hours of the final day of quarantine), or 10 days without a test if the individual remains asymptomatic. This guidance is based on research showing that a person with COVID is most infectious in the initial 7-10 day period.  

Under the new CDC guidance for “close contact” quarantine:

• An individual with no symptoms can end quarantine 10 days after exposure without testing;
• An individual with no symptoms can end quarantine 7 days after exposure if they have a negative result from a COVID test collected no earlier than day five of the quarantine.

The Wisconsin’s Department of Health Services also updated its guidance to permit reduced quarantine options for asymptomatic individuals. Effective December 7, 2020, the Wisconsin guidance provides that:

• An individual with no symptoms can end quarantine 7 days after exposure with a negative COVID test administered no earlier than day six of quarantine (vrs. CDC: day five).
• Point of care antigen tests are acceptable, but PCR (non-rapid) tests are preferable.
• High-risk settings, such as long-term care facilities, should assess the use of the shortened quarantine on a case-by-case basis in light of the continuing, though significantly reduced risks of post-quarantine transmission.

Because a modest risk of developing COVID-19 remains for a full 14 days after exposure, an individual ending quarantine before 14 days should continue to monitor their health, practice social distancing, wear a face covering and immediately isolate and notify health officials if they do develop symptoms.

Per the CDC: workers in critical infrastructure industries may continue working after exposure to COVID-19 (rather than quarantining) as long as they remain asymptomatic. However, the CDC recently indicated that this should be used only as “a last resort and only in limited circumstances, such as when cessation of operation of a facility may cause serious harm or danger to public health or safety.” This limitation on the scope of allowable work in critical industries was based on scientific evidence regarding the transmission risk from asymptomatic individuals as well as the ongoing community transmission risk in many areas.

If COVID-exposed but asymptomatic critical infrastructure workers are required to work, the CDC to applies the following guidelines:

• Employees should self-screen at home prior to reporting to work. They should not report to work if they have COVID-19 symptoms, a temperature equal to or higher than 100.4 F, or are waiting for the results of a viral test.
• Employers should conduct an on-site symptom assessment, including a temperature check, prior to each work shift.
• The employee should self-monitor for symptoms under supervision of the employer’s occupational health program.
• The employee should wear a face mask or covering (which may be required under local or state mandates in any case).
• To the extent possible, the employee should maintain a distance of 6 feet from others in the workplace.
• Work spaces such as offices, bathrooms, common areas, and shared equipment should be cleaned and disinfected routinely.
• If the employee becomes ill, they should be sent home immediately and their workspace cleaned and disinfected. Other employees who came into close contact with the employee during the two days prior to any symptoms would themselves be considered exposed and subject to the guidelines above.

The CDC recommends that critical infrastructure employers reduce the need to reintegrate exposed critical infrastructure workers by:

• Identifying and prioritizing job functions essential for continuous operation,
• Cross-training employees to perform critical job functions so the workplace can operate even if key employees are absent, and
• Matching critical job functions with other equally skilled and available workers who have not experienced an exposure to a person with confirmed COVID-19.

If you have any questions regarding the CDC COVID-19 guidance, emergency paid leave under the Families First Act, or any other employment related questions, feel free to contact Dave McClurg at 414.559.7704 or dmcclurg@petriepettit.com.