IDPH and CDC Update Guidance on School Exclusions and Close Contacts

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The Illinois Department of Public Health (IDPH) has again updated its COVID-19 Interim Exclusion Guidance as well as its general Interim Guidance for Pre-K-12 Schools. The updated guidance documents include several revisions, including specifying the type of negative COVID-19 test that may be accepted prior to allowing a symptomatic student or staff member to return to school. IDPH also recommends that all close contacts that remain asymptomatic be tested between 5-9 days after exposure to a positive case, but that asymptomatic close contacts with a positive test result within the last 90 days do not need to re-isolate. The CDC has also updated its definition of a “close contact” to clarify that a “close contact” is someone who has been within 6 feet of an individual who has tested positive for COVID-19 for a cumulative total of 15 minutes over the course of a day, a position that aligns with IDPH’s current definition of close contact. We provide a summary of the particular updates below:

  • IDPH COVID-19 Interim Exclusion Guidance (Decision Tree for Symptomatic Individuals in Pre-K, K-12 Schools and Day Care Programs)
    • Specifies that if a symptomatic individual is a close contact of a confirmed case, if the school is experiencing an outbreak, or if the local health department is requiring validation due to community transmission levels, symptomatic individuals may only return to school with a negative COVID-19 diagnostic test if they have a negative “RT-PCR” COVID-19 test result. In other situations, a negative rapid molecular (rapid PCR) or negative antigen test is acceptable.
    • Notes that test specimens collected 48 hours prior to symptom onset, after symptom onset, or while symptoms are present are acceptable for determining school exclusion status.
    • Clarifies that if testing is not performed for a symptomatic individual due to the clinical judgment of the healthcare provider, that such individuals may only return to school if they have a medical note documenting that there is no clinical suspicion for COVID-19 infection and indicating an alternative diagnosis with exclusion consistent with that diagnosis.
    • Includes the following guidance from CDC as an additional resource for nurses and healthcare providers: “CDC Indicators for Dynamic School Decision-Making.”
  • Public Health Interim Guidance for Pre-K-12 Schools and Day Care Programs for Addressing COVID-19
    • States that persons with a recent positive COVID-19 test result who had a prior positive viral test within the past 90 days do not need to re-isolate if they are asymptomatic. Any such individuals who are symptomatic should consult with the local health department regarding isolation procedures.
    • Also states that any close contacts that have had a lab-confirmed COVID-19 diagnosis within the past 90 days do not need to be quarantined.
    • Clarifies that COVID-19 diagnostic testing is recommended for close contacts that develop symptoms, and that all close contacts are recommended to be tested between 5-9 days after exposure to a positive case, even those that remain asymptomatic.  
    • Explains the next safest levels of respiratory protection for a nurse screening a symptomatic student if a fit-tested N95 respirator is not available.
    • Reiterates that other household members of a symptomatic individual in the school must be sent home until an alternative diagnosis is made or negative result received for the symptomatic individual.
    • States that schools should provide local health departments with reporting on the number of children excluded and methods used to return to school as requested by the local health department.
  • CDC Definition of “Close Contact
    • Now defines a “close contact” 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 2 days before illness onset (or for asymptomatic patients, two days prior to test specimen collection), until the time the patient is isolated. “

In addition to stating that a “close contact” is someone who was within six feet of someone who has COVID-19 for a total of 15 minutes, the CDC’s guidance on “when to quarantine” states that “close contacts” also include the following:

  • Individuals who provided care at home to someone who is sick with COVID-19
  • Individuals who had direct physical contact with the person (hugged or kissed them)
  • Individuals who shared eating or drinking utensils
  • Individuals on whom a person with COVID-19 sneezed or coughed, or somehow got respiratory droplets on

The CDC’s guidance for K-12 schools has also been updated to reflect the new definition of “close contact” and notes various factors to consider when defining close contacts.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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