Media, CDC, and DPH Combine to Confuse Georgia Providers Regarding Quarantine Guidance

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With much fanfare earlier this month, mass media outlets touted revised guidance from the Centers for Disease Control and Prevention (CDC) that individuals who have been fully vaccinated can “skip” quarantine if they become exposed to someone with suspected or confirmed COVID-19.  As is often the case, however, the early headlines did not convey the whole story. Yes, under the CDC guidance, individuals exposed to someone with suspected or confirmed COVID-19 are not required to quarantine, but only if they meet certain criteria.  Specifically, they must (1) be fully vaccinated, meaning that two weeks or more must have elapsed since they received their final dose of vaccine; (2) be within three months following receipt of that final dose; and (3) have remained asymptomatic since the current COVID-19 exposure.  More importantly, however, the CDC seemed to limit the application of the guidance for healthcare personnel only to situations in which such fully vaccinated personnel are needed to alleviate staffing shortages, and stated that it does not apply at all to vaccinated inpatients or residents in healthcare settings.

Shortly after the CDC released its guidance, the Georgia Department of Public Health (DPH) issued its own comprehensive quarantine guidance that only added to the confusion for providers in the state.  The DPH guidance, like the CDC guidance, is directed to a wide variety of audiences.  As a result, long-term care (LTC) and other healthcare providers must wade through provisions of general application, locate those portions that apply to health care settings, then refer back and forth within the narrative—and even to additional guidance documents—to determine the protocols they should be following with respect to both vaccinated and unvaccinated patients/residents and staff.  More importantly, the DPH guidance lacks clear, concise protocols for providers to follow.

The DPH guidance provides the following as applied to residents and staff of Georgia LTC facilities, which include nursing homes, assisted living facilities, personal care homes, and similar facilities:

LTC Residents – If exposed to someone with confirmed or suspected COVID-19, a resident, regardless of vaccination status, should remain in quarantine for 14 days, even if the resident remains asymptomatic.  During such time, the resident’s health should be monitored, i.e., the resident’s temperature should be taken twice a day and the resident should be observed for symptoms associated with COVID-19.

DPH notes that a person who has clinically recovered from COVID-19 and then is identified as a contact of a new case within three (3) months of symptom onset or positive test result, need not quarantine; however, because this provision is in a section of the guidance that has provisions applicable to the general public and provisions applicable to LTC facilities and other congregate settings, it is open to interpretation whether it applies to LTC residents.  Given the extremely conservative approach taken with respect to LTC residents by both CDC and DPH, however, providers should consider erring on the side of caution with their policies and practices in this regard.

Other Senior Living Residents – The guidance, as drafted, treats residents in non-healthcare senior living settings differently than residents in healthcare settings.  Residents in non-healthcare senior living settings, such as senior housing and the residential portion of life plan/continuing care retirement communities, would follow the portion of the guidance applicable to the general public:

  • Unvaccinated Senior Living Residents – The DPH guidance recommends that an exposed resident quarantine for 14 days and monitor his or her health; however, the resident may end quarantine after seven (7) full days have passed since exposure only if all three of the following criteria are met:
    • The resident does not experience any symptoms during the monitoring period;
    • The resident is tested using a PCR or antigen test, the specimen for which should not be collected before day five of the quarantine; and
    • The resident tests negative.

If the resident is unable to be tested for COVID-19 during the quarantine period, the resident may discontinue the quarantine after day 10 if he or she remains asymptomatic.  The resident should continue to monitor his or her health for the full 14-day period.

  • Fully Vaccinated Senior Living Residents – A senior living resident who has been fully vaccinated do not need to quarantine so long as the three criteria specified in the CDC guidance are met. Such residents, however, should monitor themselves for symptoms for 14 days.  Residents that do not meet the CDC criteria should follow the protocol applicable to unvaccinated senior living residents.

Staff of LTC Facilities – The DPH quarantine guidance does not specifically provide protocols for quarantine of vaccinated or unvaccinated staff of LTC facilities and other healthcare facilities though it states under the heading of “Considerations During Quarantine” that staff may continue to work, in consultation with their workplace occupational health program and if necessary to ensure adequate staffing if they meet or abide by certain requirements.  Although this statement is generally consistent with the CDC guidance, that guidance is clearly directed only to vaccinated personnel.  The DPH guidance is silent and thus creates ambiguity for providers.

Finally, the DPH guidance directs healthcare workers who become sick to follow its January 4, 2021 Return to Work guidance.  The return to work guidance states that symptomatic workers can return to work after:

  • At least 10 days have passed since symptoms first appeared (up to 20 days for workers with severe illness);
  • At least 24 hours have passed since last fever without the use of fever-reducing medications; and
  • Symptoms have improved.

For Georgia providers still scrambling to respond to COVID-19, misleading mass media headlines and an overly broad approach in both the CDC and DPH guidance to the issue of vaccination and its effect on quarantine for the entire spectrum of individuals, both inside and outside of healthcare settings, creates confusion for LTC and other healthcare providers.  A more useful approach would have been to address the issue in separate guidance applicable only to health care settings.  More importantly, however, as more and more guidance is issued by public health authorities, the need for a thorough review and analysis of any new guidance in light of existing (and possibly contradictory) guidance is warranted to ensure that providers receive clear direction.  Without clarity, providers will have difficulty parsing the recommendations and adjusting their operating protocols accordingly.

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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