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COVID-19 Development – CDC Issues New Recommendations for Fully Vaccinated Individuals

May 14, 2021

CDC Interim Public Health Recommendations for Fully Vaccinated People

On May 13, 2021, the Centers for Disease Control and Prevention (CDC) revised its Interim Public Health Recommendations for Fully Vaccinated People.  Since the CDC’s April 27, 2021, guidance for vaccinated people, which Crowell & Moring summarized here, the CDC has loosened its recommendations for individuals who are fully vaccinated.  The key changes are that (1) fully vaccinated people no longer need to wear a mask or physically distance in any setting, except where required by federal, state, local, tribal, or territorial laws, rules, and regulations, including local business and workplace guidance; and (2) fully vaccinated people need not take a COVID test following a known exposure, unless they are residents or employees of a correctional or detention facility or a homeless shelter.

Who is Fully Vaccinated?

The CDC considers a person to be fully vaccinated beginning two weeks after they have received the second dose in a 2-dose series (Pfizer-BioNTech or Moderna), or beginning two weeks after they have received a single-dose vaccine (Johnson and Johnson [J&J]/Janssen).  Qualifying vaccines are the COVID-19 vaccines currently authorized for emergency use by the U.S. Food and Drug Administration—Pfizer-BioNTech, Moderna, and Johnson and Johnson (J&J)/Janssen COVID-19 vaccines—or COVID-19 vaccines that have been authorized for emergency use by the World Health Organization (e.g., AstraZeneca/Oxford).  There is currently no post-vaccination time limit on fully vaccinated status.

What is the General Guidance for Vaccinated People?

The CDC has recognized that indoor and outdoor activities pose a minimal risk to fully vaccinated people and have a reduced risk of transmitting COVID-19 to unvaccinated people.  The CDC now recommends the following for fully vaccinated people:

  • Fully vaccinated people should still get tested if experiencing COVID-19 symptoms
  • Fully vaccinated people should not visit private or public settings if they have tested positive for COVID-19 in the prior 10 days or are experiencing COVID-19 symptoms.
  • Fully vaccinated people should continue to follow any applicable federal, state, local, tribal, or territorial laws, rules, and regulations.

The CDC still recommends prevention measures for unvaccinated people, including social distancing and wearing a mask.

What Travel Restrictions Exist for Vaccinated People?

In general, all travelers must continue to wear a mask on planes, buses, trains, and any other forms of public transportation traveling into, within, or out of the United States and in U.S. transportation hubs such as airports and stations.  While the CDC has lessened its travel restrictions, as detailed below, travelers must also comply with local, state, and territorial testing and quarantine requirements. 

For domestic travel, fully vaccinated people are not required to get a COVID-19 test before or after domestic travel.  Fully vaccinated travelers do not need to self-quarantine.

For international travel, fully vaccinated people are still required to have a negative COVID-19 test or documentation of recovery before they board a flight to the United States.  And, the CDC still recommends that all travelers get a COVID-19 test three to five days after travel.  However, fully vaccinated travelers are no longer required by the CDC to get tested before leaving the United States nor do they have to self-quarantine after travel.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Thomas P. Gies
Partner – Washington, D.C.
Phone: +1.202.624.2690
Thomas F. Koegel
Partner – San Francisco
Phone: +1.415.365.7858
Kris D. Meade
Partner – Washington, D.C.
Phone: +1.202.624.2854
Katie Erno
Counsel – Washington, D.C.
Phone: +1.202.624.2926