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The U.S. Centers for Disease Control and Prevention (CDC) has updated the activities in which a “fully vaccinated” individual can engage. These new guidelines apply in non-healthcare settings.

To qualify as “fully vaccinated,” at least two weeks must have passed since an individual completed either (a) both doses of either the Pfizer-BioNTech or Moderna vaccines or (b) a single dose of the Johnson & Johnson vaccine. The CDC warns, however, that individuals who have a weakened immune system should continue to take all precautions previously conveyed (such as masks, physical distance, etc.) even if fully vaccinated.

If fully vaccinated, the CDC says that it is now safe to do the following:

  • gather indoors with fully-vaccinated individuals without wearing a mask or staying 6 feet apart;
  • gather indoors with unvaccinated individuals of any age from one other household without wearing a mask or staying 6 feet apart, unless any of the unvaccinated individuals or anyone with whom they live has an increased risk of severe illness from COVID-19; and
  • participate in outdoor activities and recreation without wearing a mask except in certain crowded settings and venues.

With regard to exposure, the CDC states that a fully-vaccinated individual who is exposed to someone who is COVID-19 positive does not need to quarantine, be restricted from work, stay away from others or get tested unless the fully-vaccinated individual exhibits symptoms. There is an exception for those who live in group settings (correctional facilities, etc.), and, in those instances, the CDC states that fully-vaccinated individuals need to stay away from others for 14 days even if they do not have symptoms. According to the CDC, a fully-vaccinated individual should still monitor for symptoms for 14 days following an exposure. Fully-vaccinated individuals who exhibit symptoms should isolate themselves from others and be clinically evaluated. Fully-vaccinated individuals should not visit or attend gatherings or be around others if they have tested positive for COVID-19 in the prior 10 days or are experiencing COVID-19 symptoms.

Changes with regard to travel for the fully vaccinated include the following:

  • Fully-vaccinated individuals traveling in the United States do not need to get tested before or after travel or to self-quarantine after travel.
  • Fully-vaccinated individuals need to double check requirements before leaving or re-entering the United States. However, generally, they:
    • do not need to get tested before leaving the United States unless the destination requires it;
    • still need to show a negative test result or documentation of recovery before boarding any international flight to the United States;
    • are recommended to be tested 3-5 days after international travel; and
    • do not need to self-quarantine after arriving in the United States.

Employers may want to consider adjusting their travel requirements to be consistent with these loosened restrictions.

The CDC states that fully-vaccinated individuals should continue to use good hygiene, avoid large indoor crowds, protect themselves, and wear masks on public transportation and in airports and stations.

These changes may impact and loosen work restrictions. Employers may wish to consider updating their workplace and travel restrictions accordingly.

Ogletree Deakins will continue to monitor and report on developments with respect to the COVID-19 pandemic 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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