COVID-19 Updated Contact Tracing Guidelines for Employers


COVID-19 cases are surging across the country. Public health departments are inundated with positive cases and cannot always immediately contact and assist employers with internal contact tracing whenever an employee tests positive. Employers should therefore stay informed of existing contact tracing guidelines and be prepared to act as soon as the employer becomes aware of a positive case at the workplace, regardless of whether and when the employer is contacted by the public health department.

Contact tracing means identifying all individuals that were in “close contact” with the infected individual and asking those individuals to quarantine for a period of 14 days from the date of last exposure to the infected individual.

The CDC recently updated its guidance on the definition of “close contact.” The CDC defines “close contact” as “someone who was within 6 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, 2 days prior to test specimen collection) until the time the patient is isolated.” The CDC also makes clear that a “close contact” should be determined “irrespective of their use of cloth face coverings.”

The CDC’s new guidelines depart from prior health department guidelines in two significant ways. First, close contacts must be determined without regard to whether the infected individual and/or the exposed individual were wearing masks as the time of exposure. Second, the requisite 15 minutes are measured cumulatively, not consecutively. So shorter exposures throughout the day, which ultimately add up to 15 minutes, will qualify under the definition of “close contact.”

These guidelines undoubtedly will expand the number of individuals that will be subject to quarantine following exposure to an infected individual. Unfortunately, employers may experience staffing shortages and other difficulties when implementing these measures. At the same time, however, the guidelines will also, hopefully, assist in bringing this pandemic under control.

Underwood Law Firm is available to answer any specific questions our clients have about COVID-19 issues. Please reach out to your contact at Underwood Law Firm or to Autum Flores at with any questions or concerns.

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