On January 12, 2022, the California Department of Public Health (“CDPH”) updated its COVID-19 Public Health Guidance for K-12 Schools in California. The new guidance modified the student quarantine procedures. It also introduced a new Group-Tracing Approach to Students Exposed to COVID-19 in a K-12 setting. The updated CDPH guidelines states that schools may consider following quarantine recommendations found in sections 7-9 of the guidance or the Group-Tracing Approach. Both sets of recommendations are summarized below. Please note that schools should also follow their local county guidelines as some counties may have more stringent quarantine requirements than the CDPH.
A. Recommendations for Student Quarantine
The CDPH K-12 guidance separates the recommendations for quarantines into two groups: 1) students who have completed the primary series of COVID-19 vaccines or were previously infected with (laboratory confirmed) COVID-19 within the last 90 days and 2) students who have not completed the primary series of COVID-19 vaccines and were not previously infected. Completion of the primary series does not include boosters.
Quarantine for these students is not recommended based on a close contact exposure. As a result, these students may remain in school and participate in all school activities. However, if symptoms develop, these students should be tested three-five days after exposure and stay home.
For students who have not completed the primary series of the COVID-19 vaccine and have not had COVID-19 within the past 90 days, there are three possible quarantine options.
a. Option 1: Modified Quarantine
The first option is a “modified quarantine.” It applies when students have a close contact (more than 15 minutes over a 24-hour period within 0-6 feet) in the school setting while supervised by school staff and all students were wearing a mask. The exposed students may continue to attend school during the quarantine period, as defined below, so long as they remain asymptomatic, continue to mask as required, and undergo twice-a-week testing during the quarantine period. The student must quarantine for all extracurricular activities, including sports and activities within the community setting.
b. Option 2: Standard Quarantine
The second option is a “standard quarantine” for students who do not meet the requirements for the modified quarantine because exposure occurred outside the school setting or one or both students were not wearing a face covering. Standard quarantine means that the student will stay at home for five days. The quarantine ends after day five if symptoms are not present and a diagnostic specimen is collected on day five or the student later tests negative. If the student is unable to test or chooses not to test, and symptoms are not present, quarantine can end after day 10.
c. Option 3: No Quarantine
The third option is to follow the Group-Tracing Approach, as described below.
B. Group-Tracing Approach to Students Exposed to COVID-19 in a K-12 Setting
Exposed students, regardless of vaccination status or prior infection, may continue to take part in all aspects of K-12 schooling, including sports and extracurricular activities, as long as they adhere to all testing and guidance as recommended by the Group-Tracing Approach, and report positive test results to the school. However, exposed students may not participate in schooling if they develop symptoms or test positive for COVID-19. Exposed students must also isolate in accordance with CDPH guidance if they develop symptoms or receive a positive test result.
All students who were exposed to COVID-19 should be tested within three-five days after their last exposure. In the event of a wide-scale or repeated exposures, broader (e.g., grade-wide or campus-wide) once weekly testing may be considered until exposure events become less frequent. Any FDA-approved antigen diagnostic test, PCR diagnostic test, or pooled PCR test is acceptable for student testing. If a student was recently infected within the last 90 days, antigen testing is strongly recommended. The CDPH also recommends repeat antigen or confirmatory molecular testing for those who receive a negative result but are still exhibiting COVID-19 symptoms.
Under the Group-Tracing Approach, schools should notify students who spent more than 15 minutes (within a 24-hour time period) in a shared indoor airspace (e.g., classroom) with someone with COVID-19 during the infectious period. Rather than adopting contract tracing, CDPH recommends notifying “groups” of exposed students, such as classmates, teammates, or cohorts. Notification should be provided to all individuals considered exposed, regardless of vaccination status or if they were recently infected. CDPH has provided a sample notification letter.
LCW will continue to track federal, state, and local guidance closely. Please reach out to an LCW attorney with any questions.