CDC updates to K-12 Guidance are in line with CDPH Guidance

On Aug. 11, the Centers for Disease Control and Prevention issued updated COVID-19 guidance for K-12 schools and early care and education programs. The revisions to the guidance largely tracks guidance issued by the California Department of Public Health on June 30 (effective July 1). Some of the guidance remains unchanged (e.g., ventilation, cleaning, hygiene). The largest change to the guidance, from both CDC and CDPH, is that neither recommends the quarantine of individuals (both students and employees) who are asymptomatic close contacts for COVID-19. Further, neither guidance recommends using cohorts.

A comparison of the guidance from both agencies follows. Local educational agencies should follow CDPH guidance, except where CDC guidance is more restrictive. In addition, LEAs should follow any local public health guidance if it is more restrictive than CDC or CDPH guidance. LEAs must also continue to follow CalOSHA COVID-19 Regulations with respect to their employees.

Managing cases

  • Symptoms of COVID-19

CDC guidance states that individuals who have or develop COVID-19 symptoms at school should be asked to wear a mask while in school buildings and be sent home and encouraged to get tested if testing is unavailable at school. Symptomatic individuals who are unable to wear a mask (e.g., due to disability) should be separated from others until they can leave school facilities. CDPH guidance is similar. It encourages LEAs to develop standard criteria for managing individuals who develop symptoms of COVID-19, but also strongly recommends that individuals with COVID-19 symptoms wear a mask, isolate under the CDPH isolation guidance for the general public, and get tested immediately. Both CDC and CDPH recommend avoiding policies that provide incentives for attendance that could result in students or employees coming to school or work sick.

  • Positive COVID-19 test

CDC guidance states that individuals with COVID-19 must isolate away from others and not attend school/work until they have completed isolation pursuant to CDC’s isolation guidance for the general public. Under the CDC guidance, testing is not required to return to school. It is important to note that CDC and CDPH guidance differ regarding isolation periods. Under CDC guidance, isolation can be discontinued at day five if symptoms are improving and the individual is fever-free for 24 hours without fever-reducing medications. (Certain populations, including those who had shortness of breath as a COVID-19 symptom or those who have compromised immune systems must isolate for 10 days.) However, under CDPH guidance, the isolation period is 10 days, and can only be shortened if the person tests negative on day five or later if symptoms are improving and the individual is fever-free for 24 hours without fever-reducing medications. LEAs should follow the more restrictive CDPH guidance.

Exposures to COVID-19 — asymptomatic individuals

Under both the CDC and CDPH guidance, asymptomatic individuals with a known or suspected COVID-19 exposure may continue to participate in all school activities, including extracurricular activities so long as they do not develop symptoms. (For those who develop symptoms, see “symptomatic individuals,” above.) Exposed individuals should wear a mask for 10 days after the last known or suspected exposure. Testing is not required to determine the end of mask use, but CDPH recommends testing within three to five days after exposure. If not able to wear a mask, the individual should isolate for 10 days.

Masking

  • General rule

Neither guidance requires general masking for schools. CDPH’s guidance refers to its masking guidance for the general public, which strongly recommends masking in indoor settings, regardless of levels of community transmission or other factors. CDC recommends masking in schools at a high COVID-19 community level, which is defined by the CDC and based on hospitalizations and heath care system strain in a county. CDC also recommends masking in school nurses’ offices (which it considers a health care setting), regardless of the community level.

CDPH prohibits LEAs from preventing any individual from wearing a mask unless a mask would create a safety hazard. Similarly, CDC’s guidance states that LEAs should support any individual who chooses to wear a mask.

  • At-risk students

CDC’s guidance states, “[s]chools with at-risk students for getting very sick with COVID-19 must make reasonable modifications when necessary to ensure that all students, including those with disabilities, are able to access in-person learning.” This could include requiring masking in certain settings, including classrooms.

  • Individuals with close contact to a COVID-19 case

Both CDC and CDPH guidance recommend those who have a known or suspected exposure to COVID-19 to wear a mask for 10 days from their last exposure, regardless of vaccination status.

Testing

Neither CDPH nor CDC guidance require routine testing at school (except for those who must test under the California vaccination order for employees). CDC recommends testing for schools in counties with high community levels for high-risk activities (e.g., close contact sports, band/choir/theater activities), before and after large events (e.g., prom, group travel), and in response to an outbreak. CDC guidance also states that LEAs may consider testing for students who are immunocompromised or have complex medical conditions in counties with medium or high community levels. Similarly, CDPH recommends testing for students and employees prior to returning to school following long breaks (e.g., summer, winter break).

CDC guidance does not suggest a particular type of testing, but CDPH guidance recommends using antigen tests as the primary type of testing rather than point of care (PCR) tests.

Outbreaks

CDC guidance provides examples of how to reduce transmission due to an outbreak without closures, including requiring masks, increasing ventilation, screening testing and contact tracing. CDC recommends consultation with local public health authorities in the case of an outbreak. Similarly, CDPH guidance provides that temporary school or classroom closures due to outbreaks should only be a last result, in consultation with local public health authorities.

In conclusion, the guidance from CDC and CDPH contain minor differences. It is important that LEAs familiarize themselves with the most restrictive requirements and recommendations, including those from their local public health authorities.