CDC Releases Interim Public Health Recommendations for Fully Vaccinated People in Non-Healthcare Settings
On March 8, 2021, the United States Centers for Disease Control and Prevention issued Interim Public Health Recommendations for Fully Vaccinated People for individuals who have been fully vaccinated against COVID-19. With COVID-19 vaccines becoming more widely distributed, the new recommendations address how to manage vaccinated individuals in non-healthcare settings, including social gatherings, contact tracing and quarantine practices. For employers, the following are key points that should be considered in revising workplace practices and policies.
- The CDC recommendations apply only to “fully vaccinated” persons, defined by the CDC as those who are more than two weeks from having received the second dose of a two dose vaccine (Pfizer or Moderna) or a single dose vaccine (Johnson & Johnson/Janssen).
- While the CDC continues to recommend that all persons wear face coverings and observe social distancing when around unvaccinated individuals outside of a single household, in certain circumstances, the recommendations ease face covering requirements for people who have been fully vaccinated. In particular, the CDC advises that fully vaccinated people need not wear masks or observe social distancing during indoor visits with other fully vaccinated people. At the same time, the CDC recommends that “visits or small gatherings likely represent minimal risk to fully vaccinated people,” though vaccinated people should be mindful of the increased risks to others in medium or large gatherings with people from multiple households.
- The recommendations provide an exception for fully vaccinated people from certain quarantine requirements. The CDC states that vaccinated people who are exposed to a known or suspected case of COVID-19 but have no symptoms “do not need to quarantine or be tested . . . as their risk of infection is low,” though such persons still should monitor for symptoms for 14 days following the exposure and isolate if they begin to experience symptoms.
- In the case of employees of “non-healthcare congregate settings and other high-density workplaces,” such as manufacturing environments and meat and poultry processing plants, the CDC advises that vaccinated people who are exposed to an infected person need not quarantine, but the CDC recommends such persons get tested after the exposure and that they follow routine workplace screening programs.
- The CDC emphasizes that fully vaccinated people should continue to take precautions in public and when around unvaccinated people outside of their own households, such as by wearing face coverings and physical distancing. The CDC notes that vaccinated people also should continue to “[f]ollow guidance issued by individual employers.”
- The CDC is not altering its guidance with respect to travel for vaccinated people at this time.
For employers as well as individuals, the impact of these new recommendations is significant. First, employers can update their protocols for contact tracing and quarantine and testing requirements, while remaining mindful of guidance from state and local public health authorities. Second, employers may want to consider whether and how to track employee vaccinations. For more information on that topic, see MEA’s prior alert. Finally, the new recommendations present an opportunity for employers to talk again to their employees about the benefits of vaccination and may cause some employers to revisit the extent to which they encourage or incentivize employees to be vaccinated. For more information on that topic, see MEA’s prior alert.
Employers should consult with experienced human resources professionals and/or labor and employment counsel with any questions regarding pandemic-related policies or practices. For MEA members, the Hotline and a Member Legal Services attorney are available to provide this assistance.
Amy G. McAndrew, Esquire
Director of Legal and Compliance Services
MidAtlantic Employers’ Association
*This Alert is provided for general informational purposes only and does not constitute legal advice.