CDC Issues New Guidance for Fully Vaccinated Individuals

May 3, 2021

On Tuesday, April, 27, 2021, the Centers for Disease Control and Prevention (CDC) issued Interim Public Health Recommendations for Fully Vaccinated People.  The guidance enumerates various situations in which fully vaccinated individuals may forgo wearing a mask, and circumstances in which they may refrain from quarantining and testing.  The guidance considers individuals “fully vaccinated for COVID-19 ≥2 weeks after they have received the second dose in a 2-dose series (Pfizer-BioNTech or Moderna), or ≥2 weeks after they have received a single-dose vaccine (Johnson and Johnson (J&J)/Janssen).”  The guidance includes various specific recommendations.

Aspects of the new guidance provide good news to U.S. employers, including the elimination of the workplace quarantine recommendations for fully vaccinated people.  Traveling for business will also be easier now that the CDC permits domestic fliers to refrain from testing before or after travel or self-quarantine after travel.  International travel is likewise streamlined with fully vaccinated individuals exempt from testing before leaving the U.S. (unless required by the destination) and self-quarantine after arriving back in the U.S.

The new CDC guidance raises several critical questions for employers.  The CDC recommends that fully vaccinated people continue to take precautions in “indoor public settings” without providing a definition for that phrase.  The CDC also recommends fully vaccinated people follow policies implemented by their employers as well as applicable state and local law.  Recent rollbacks of COVID-related restrictions in certain states will continue to present challenging interpretative questions for employers operating in those jurisdictions.  Unlike other CDC COVID-related guidance, these recommendations are not intended to be principally directed to the private sector workplace.  We hope that additional guidance, from agencies including CDC, EEOC, and OSHA, will provide important further clarification to employers as they begin to implement back-to-work policies.

Thomas P. Gies
Partner – Washington, D.C.
Phone: +1 202.624.2690

Eric Su
Partner – New York
Phone: +1 212.803.4041

Katie Erno
Counsel – Washington, D.C.
Phone: +1 202.624.2926

Suzanne E. Rode
Counsel – San Francisco
Phone: +1 415.365.7276

Jessica S. Nam
Associate – Washington, D.C.
Phone: +1 202.624.2922


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