Person with blue medical gloves holding syringe and vial.

On December 27, 2021, the U.S. Centers for Disease Control and Prevention (CDC) updated its recommendation for lengths of quarantine and isolation in light of what is currently known about COVID-19 and the Omicron variant. The CDC’s recommendations for both quarantine and isolation periods have been shortened, and the CDC is now recommending quarantine for certain fully-vaccinated close contacts of individuals who are known to be COVID-19 positive.

The CDC recommends isolation periods of five days for those who test positive for COVID-19 and are asymptomatic or cease to be symptomatic in the five-day period. The CDC notes that those with fevers should continue to quarantine until the fever resolves.

The CDC previously revised its quarantine guidance for fully-vaccinated individuals. In the latest additional revisions to the recommendations, the CDC recommends quarantine for five days after close contact and masking for an additional five days (provided no symptoms develop) for individuals who:

  • are unvaccinated,
  • completed the primary series of the Pfizer or Moderna vaccines more than 6 months ago and have not received a booster, and
  • completed the primary series of the Johnson & Johnson/Janssen vaccine more than 2 months ago and have not received a booster.

Only individuals who have received a booster shot, completed the primary series of the Pfizer or Moderna vaccines within the last 6 months, or completed the primary series of the Johnson & Johnson/Janssen vaccine within the last 2 months may forego quarantine, but such individuals should mask for 10 days after close contact with an individual known to have COVID-19. According to the CDC, these individuals need not quarantine if they remain symptom free. The CDC further recommends that all individuals who have had close contact with someone known to have COVID-19 get tested 5 days after exposure, regardless of vaccination status.

Employers may want to review and revise their COVID-19 policies to reflect this updated guidance on quarantine and isolation periods. Many employers have followed CDC guidance in not requiring fully-vaccinated individuals to quarantine if asymptomatic after a close contact with someone known to have COVID-19. This announcement may require employers to examine whether a fully-vaccinated employee who is a close contact has received a booster shot and/or how long it has been since the employee was fully vaccinated. Some employers will want to take advantage of the shortened quarantine and isolation periods.

The CDC’s guidance does not supersede state or local regulations or rules. While the federal Occupational Safety and Health Administration (OSHA) emergency temporary standard (ETS) incorporated the CDC’s isolation guidance, employers in California will want to ensure they are complying with California’s Division of Occupational Safety and Health’s (Cal/OSHA) emergency temporary standards’ requirements on isolation and quarantine.

Ogletree Deakins will continue to monitor and report on developments and will post updates in the firm’s Coronavirus (COVID-19) Resource Center as additional information becomes available. Important information for employers is also available via the firm’s webinar and podcast programs.


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