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October 2020

The CDC Expands Definition of a “Close Contact”—Employers, It’s Time to Revise Your Covid-19 Policies…Again

The U.S. Centers for Disease Control and Prevention ("CDC") recently expanded its definition of a “close contact” of someone who is infected with the coronavirus, which is now defined as:

Someone who was within six feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period starting from two days before illness onset (or, for asymptomatic patients, two days prior to test specimen collection) until the time the patient is isolated.

Under prior guidance, the CDC defined a close contact as a person who spent at least 15 consecutive minutes within six feet of an infected person, thus putting the individual at higher risk of contracting the coronavirus.

Now, as an example, someone who was within six feet of an infected person, three times for five minutes within a 24-hour period would be considered a close contact under the new definition which now counts a cumulative total of minutes.

The CDC’s significantly broadened definition of a close contact will likely have the greatest impact on hospitals, schools, nursing homes, correctional facilities, and other workplaces where individuals have several, repeated, separate interactions with an infected person totaling 15 minutes or more over the course of 24 hours.  This new definition is likely to result in significantly more individuals being identified as close contacts for purposes of a required quarantine

With this lower threshold to determine a close contact, employers should update their policies incorporating this new definition and revise contact-tracing questionnaires.  Employers should be prepared to investigate employees’ brief periods of exposure to any infected individuals, and depending on an individual’s level of exposure, there may be more individuals needing to isolate or quarantine.  For employees in most industries, the CDC recommends close contacts isolate and quarantine for a full 14 days from their last potential exposure.  This change may result in more individuals being quarantined, so employers should be prepared to handle potential staffing issues accordingly.  As part of the contact-tracing process, employers may consider asking the infected employee for a waiver to share his or her diagnosis to interview others who may have had close contact with that individual in the workplace. 

To access CDC contact tracing guidelines, please click here

Visit our COVID-19 Task Force for ongoing updates. 

Employment Law

Debra Ellwood Meppen

Employment Law