The CDC has issued long-awaited guidance on what fully vaccinated individuals can and can’t do, in the workplace and elsewhere. On March 8, 2021, the CDC issued its Interim Public Health Recommendations for Fully Vaccinated People, its first set of public health recommendations for fully vaccinated people. On the same day, the CDC posted an accompanying webpage entitled “When You’ve Been Fully Vaccinated,” detailing what has and hasn’t changed for people who are fully vaccinated.

What should employers keep top-of-mind given this new guidance?

  1. Fully vaccinated employees who have been exposed to COVID-19 do not need to quarantine if they are asymptomatic

According to the CDC, employees are considered fully vaccinated:

  • 2 weeks after their second dose in a 2-dose series (like the Pfizer or Moderna vaccines), or
  • 2 weeks after a single-dose vaccine (like Johnson & Johnson’s Janssen vaccine).

Fully vaccinated employees who have been exposed to someone with suspected or confirmed COVID-19 but who are asymptomatic do not need to quarantine or be tested for COVID-19 following the exposure, because risk of infection is low in a fully vaccinated person.

However, the CDC recommends fully vaccinated employees who do not quarantine still monitor for symptoms of COVID-19 for 14 days following an exposure. If they experience symptoms, they should follow standard protocol: isolate themselves from others, be clinically evaluated for COVID-19 (including being tested for the virus, if indicated), and they should inform their health care provider of their vaccination status.

  1. Fully vaccinated employees in high-density workplaces who have been exposed to COVID-19 do not need to quarantine if they are asymptomatic, but should be tested / screened

The guidance changes if your employees work in non-healthcare congregate settings or other high-density workplaces (such as meat and poultry processing and manufacturing plants). Fully vaccinated employees who are asymptomatic after COVID-19 exposure don’t need to quarantine, but testing following an exposure and through a routine workplace screening program (if applicable) is still recommended.

  1. Fully vaccinated employees must follow the same travel restrictions as those who are not fully vaccinated

The CDC specifically declined to update its current travel recommendations to address vaccination status. The CDC still urges people to delay domestic and international travel, but to follow CDC requirements and recommendations if they do travel. Therefore, other than recommending that individuals wait two weeks after vaccination before traveling, the new guidance does not lessen the restrictions, testing requirements, and recommendations against business travel for vaccinated employees.

The CDC continues to recommend that individuals who are fully vaccinated:

  • Wear a mask, stay at least 6 feet apart from others, and avoid crowds and poorly ventilated spaces when in public or when gathering with unvaccinated people;
  • Avoid medium or large-size gatherings;
  • Continue to watch out for symptoms of COVID-19 (especially if they’ve been around someone who is sick), and get tested and stay home if symptomatic; and
  • Follow guidance at their workplace.

The CDC stated it will update its recommendations for both vaccinated and unvaccinated people as more information becomes available about how effective vaccines are against variants and the spread of COVID-19, as well as the length of effectiveness of vaccines. Check back for updates, and for help navigating the latest developments, contact your Baker McKenzie employment attorney.