Employment Law Report

CDC Updates COVID-19 Guidance for Colleges and Universities

The CDC recently updated its COVID-19 guidance for colleges and universities.  In general, the guidance addresses ways to offer and promote the COVID-19 vaccination, guidance for institutions of higher education (“IHE”) where everyone is fully vaccinated, guidance for IHEs where everyone is not vaccinated, and general considerations for all IHEs regardless of vaccination status.  

For IHEs where all students, faculty and staff are fully vaccinated prior to the start of the semester, masks and physical distancing is not required.  However, general public health considerations such as handwashing, cleaning/disinfection and respiratory etiquette should continue to be encouraged regardless of vaccination status. When holding gatherings and events that include individuals who are not fully vaccinated such as campus visitors, IHEs should utilize appropriate prevention strategies to protect people who are not fully vaccinated.  In addition, people who are fully vaccinated do not need to undergo routine COVID-19 screening testing.  If a fully vaccinated person is exposed to someone with COVID-19, they do not need to be tested unless they are experiencing COVID-19 symptoms.  Finally, the guidance warns that COVID-19 variants are spreading in the U.S., and instructs IHEs that experience an increase in COVID-19 cases among fully vaccinated individuals to contact their local or state public health department.

IHEs that contain a mixed population of both fully and non-fully vaccinated people on campus must engage in decision making to protect the non-vaccinated.  The guidance explains that optimal implementation of layered prevention strategies should consider the following: 1) level of community transmission of COVID-19 ; 2) COVID-19 vaccination coverage, including among students, faculty, and staff; 3) implementation of a robust, frequent SARS-CoV-2 screening testing program with high participation from the unvaccinated campus population; and 4) any local COVID-19 outbreaks or increasing trends.   Additionally, IHEs with a mixed population of vaccinated individuals must create programs and policies that facilitate the adoption and implementation of prevention strategies to slow the spread of COVID-19 on campus and in the local community, including but not limited to offering and promoting vaccines, consistent and proper use of masks, physical distancing, handwashing and respiratory etiquette, contact tracing, and testing.

The full guidance is located here.