April 07, 2021 Updated COVID-19 Quarantine and Travel Guidance
KEEPING YOU INFORMED…
We are writing to provide you with a summary of recent changes to the NYS Department of Health’s (“DOH”) guidance regarding quarantine exemptions for certain individuals who have been exposed to COVID-19, and regarding changes to the NYS Travel Advisory’s post-travel quarantine requirements.[1]
Quarantine Exemption for Certain Individuals Exposed to COVID-19
The updated guidance supersedes the March 10, 2021 guidance on quarantine for community persons exposed to COVID-19.[2]
Fully-Vaccinated Individuals
Notably, the guidance eliminates the three-month limitation within which an asymptomatic and fully vaccinated person is exempt from quarantine after exposure. In other words, regardless of how long ago asymptomatic individuals achieved full-vaccination status (defined as two or more weeks following receipt of a single-dose vaccine or, for vaccines requiring two doses, two or more weeks following the second dose), they will now not need to quarantine after exposure to COVID-19. Fully vaccinated individuals who are symptomatic after exposure to COVID-19 must, however, isolate themselves, be clinically evaluated for COVID-19, and receive a COVID-19 test, if recommended by a healthcare provider.
Individuals Who Have Recovered From a
Confirmed Case of COVID-19 and Who are Not Fully Vaccinated
The quarantine exemption for asymptomatic individuals who have been exposed to COVID-19 and who previously were infected with, and recovered from, a laboratory-confirmed case of COVID-19 was not changed by the most recent guidance. Individuals who have recovered from a confirmed case of COVID-19 continue to not be required to retest and quarantine if the COVID-19 exposure is within three months after the date of the start of the individual’s COVID-19 illness (either the symptom onset date or, if asymptomatic, the date of the positive test result). However, after the three-month period, these individuals will be required to quarantine after an exposure.
Individuals Who Do Not Meet Criteria for a Quarantine Exemption
Anyone who does not meet the criteria for one of the above quarantine exemptions must quarantine for 10 days following exposure to COVID-19. Testing is not required to end quarantine if no symptoms have been reported during the 10-day quarantine period but, if any symptoms develop within 14 days after COVID-19 exposure, the individual should be immediately tested for COVID-19. Likewise, anyone who tests positive for COVID-19 must isolate for at least 10 days.
Regardless of quarantine status, all COVID-19-exposed individuals must:
• Continue to monitor symptoms daily for 14 days (from date of exposure or from first date on which the individual became aware of the exposure, whichever is later);
• Continue, for 14 days, to adhere to all recommended non-pharmaceutical interventions (e.g., hand hygiene, face coverings) regardless of vaccination status; and
• Immediately self-isolate and contact the local health department or their health care provider if symptoms develop so that they can report their change in health status and determine whether to seek testing.
NYS Travel Advisory Changes
Domestic Travelers
As of April 1, quarantine is no longer required upon return to NYS for asymptomatic domestic travelers, including healthcare providers. While not required, however, quarantine, consistent with CDC international travel recommendations,[3] is still recommended for asymptomatic domestic travelers who have not been fully vaccinated (as defined above) or who have not recovered from a laboratory-confirmed COVID-19 infection in the past three months. Symptomatic domestic travelers must immediately self-isolate and contact the local health department or their healthcare provider to determine whether to seek COVID-19 testing.
Regardless of quarantine status, all domestic travelers must:
• Continue to monitor symptoms daily for 14 days from date of arrival in NYS;
• Continue, for 14 days, to adhere to all recommended non-pharmaceutical interventions, even if fully vaccinated; and
• Immediately self-isolate and contact the local health department or their health care provider if symptoms develop so that they can report their change in health status and determine whether to seek testing.
International Travelers
All international travelers arriving in the U.S.A. must either quarantine for seven days and have a negative COVID-19 test three to five days after arrival or quarantine for 10 days without a COVID-19 test. These requirements apply to international travelers arriving in, or passing through, NYS, regardless of vaccination status, recovery from a previous COVID-19 infection, or healthcare worker or essential worker status.[4]
Conclusion
Employers should update their existing COVID-19 screening questionnaires and related COVID-19 policies and procedures to be consistent with these changes. Please do not hesitate to contact Alyssa Zuckerman at alz@lambbarnosky.com or one of our other attorneys at 631-694-2300 if you have any questions regarding the information contained in this memorandum or would like assistance with updating your COVID-19 screening questionnaire or other COVID-19-related policies and procedures.
THIS MEMORANDUM IS MEANT TO ASSIST IN GENERAL UNDERSTANDING OF THE CURRENT LAW. IT IS NOT TO BE REGARDED AS LEGAL ADVICE. THOSE WITH PARTICULAR QUESTIONS SHOULD SEEK THE ADVICE OF COUNSEL.
[1] The DOH’s April “Update Health Advisory: Quarantine for Community Persons Exposed to COVID-19” is available at: https://coronavirus.health.ny.gov/system/files/documents/2021/04/updated_interim_guidance_for_community_quarantine_april12021.pdf. The DOH’s April “Updated Interim Guidance for Quarantine Restrictions on Travelers Arriving in New York State” is available at: https://coronavirus.health.ny.gov/system/files/documents/2021/04/update_interim_travel_advisory_april12021.pdf.
[2] For details on the earlier guidance, please see our March 16, 2021 memorandum.
[3] The CDC’s international travel quarantine period is either seven days with a COVID-19 test three to five days after arriving in the U.S.A., or 10 days without a COVID-19 test.
[4] An exception exists for travelers from Canada crossing at land borders, provided their travel is done in accordance with a current federal agreement between the governments of the U.S.A. and Canada.
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