On Monday, March 8, 2021, the Centers for Disease and Control and Prevention (CDC) released its first set of public health recommendations for individuals fully vaccinated against COVID-19, titled “Interim Public Health Recommendations for Fully Vaccinated People.” The CDC’s newly published guidelines are intended to replace the CDC’s existing public health guidance specifically for those individuals fully vaccinated for COVID-19. By “fully vaccinated”, CDC means ≥2 weeks after an individual has received the second dose in a 2-dose series (Pfizer-BioNTech or Moderna), or ≥2 weeks after an individual has received a single-dose vaccine (Johnson and Johnson [J&J]/Janssen). The updated guidance includes specific recommendations for vaccinated individuals in the non-healthcare workplace, public spaces and private and/or family settings. While the CDC guidance is only intended to provide recommended best practices, it is anticipated that the CDC’s newest guidance will be relied on by states, municipalities, school systems, and private employers as these entities continue to update and implement their own respective health guidance and COVID-19 policies and protocols.
According to the updated guidelines, vaccinated persons can now engage in a number of new activities, including:
- Visiting with other fully vaccinated people indoors without wearing masks or physical distancing;
- Visiting with unvaccinated people from a single household who are at low risk for severe COVID-19 disease indoors without wearing masks or physical distancing; and
- Refraining from quarantine and testing following a known exposure to COVID-19 if asymptomatic.
Notably, the new guidelines leave in place many of CDC’s existing recommendations for both vaccinated and non-vaccinated individuals. For example, the CDC recommends that fully vaccinated individuals continue to wear a mask in public, physical distance, avoid crowds and avoid poorly ventilated spaces. In addition, the CDC is continuing to recommend that vaccinated individuals delay domestic and international travel, and, if they do travel, continue to follow all CDC requirements and recommendations when doing so.
CDC’s guidelines for vaccinated individuals include a number of implications for private employers. In the context of non-healthcare workplaces, the CDC is now recommending that fully vaccinated employees do not need to quarantine following a known or suspected exposure to COVID-19 in the workplace unless that the vaccinated individual develops “COVID-like symptoms.” However, the guidelines still recommend that vaccinated persons receive testing “through routine workplace screening programs” following an exposure to COVID-19. Notably, CDC’s no quarantine recommendation does not extend to vaccinated employees working in congregate settings or other high-density workplaces (e.g., meat and poultry processing and manufacturing plants), and as a result vaccinated employees in congregate work environments should continue to adhere to the quarantine requirements following exposure. Employers should therefore evaluate their respective work environment to determine the appropriate quarantine procedures for employees who have received a vaccine. Under the guidelines, vaccinated individuals also need to comply with any existing COVID-19 health and safety rules issued by their employer. Thus, an employee’s vaccination status should not allow the employee to avoid his or her workplaces’ COVID-19 policies and procedures. Finally, CDC’s new guidelines do not update the CDC’s prior recommendation (issued December 30, 2020) regarding business travel. The CDC is continuing to recommend that employers “minimize non-essential travel” for all employees and, if resuming non-essential travel, ensure their employees continue to follow all state and local COVID-19 regulations and guidance regardless of their vaccination status.
In the accompanying scientific brief to its newly released guidance, the CDC cites to existing studies demonstrating the highly effective nature of the approved mRNA COVID-19 vaccines against SARS-CoV-2 infection (including both symptomatic and asymptomatic infections). Despite early evidence of the effectiveness of the approved vaccines, the CDC noted that only “approximately two-thirds of U.S. adults state that they [are] at least somewhat likely to receive a COVID-19 vaccine (or had received one already).” Because maintaining requirements to continue COVID-19 prevention measures after vaccination “may disincentive vaccine uptake,” the CDC explained that its new guidance intends to communicate additional advantages, to the individual and the community, from vaccination. The CDC advised that its guidance for vaccinated individuals will continue to be updated and modified “based on the level of community spread of SARS-CoV-2, the proportion of the population that is fully vaccinated, and the rapidly evolving science on COVID-19 vaccines.”