As more healthcare employees receive their COVID-19 vaccinations, questions about when vaccinated healthcare employees can return to work if experiencing COVID-19 symptoms continue to arise.  Coupled with ongoing staffing shortages in the industry, the need for employees to return to work when safe to do so is a pressing concern for many healthcare employers.

To help, the U.S. Centers for Disease Control and Prevention (CDC) issued updated guidance on strategies for evaluating and managing post-vaccination signs and symptoms, which may be challenging to distinguish from the signs and symptoms of COVID-19 or other infectious diseases.  Vaccinated or not, healthcare employees must continue to abide by current infection control measures, but this updated guidance provides clarity on returning vaccinated employees to work even when they may be experiencing both COVID-19 vaccination-related and COVID-19 symptoms.

The CDC’s updated guidance recommends the following return to work strategies for healthcare personnel who experience post-vaccination systemic signs and symptoms:

  • If vaccinated within the last three days, a vaccinated employee experiencing symptoms following the vaccination common to the vaccination and COVID-19 (g., fever, fatigue, headache, chills, muscle and joint pain) who are not known to have unprotected exposure in the previous 14 days, may return to work without testing if they feel well enough to do so. More on fevers below.  If symptoms are not improving or persist for more than two days, the vaccinated employee should be excluded from the workplace and viral testing for COVID-19 should be considered.
  • If the vaccinated employee develops symptoms only related to COVID-19 and not vaccination (g., cough, shortness of breath, rhinorrhea, sore throat and loss of taste or smell), the employee should be excluded from the workplace and the CDC’s general criteria on returning to work for healthcare personnel should be followed.
  • Vaccinated employees with fevers should ideally be excluded from the workplace pending further evaluation. In the case of current or anticipated critical staffing shortages, vaccinated employees with fever and systemic signs and symptoms limited only to those observed following vaccination could be considered for work if they feel well enough and are willing.  In such case, the vaccinated employees should be re-evaluated, and viral testing for COVID-19 should be considered, if the fever does not resolve within two days.
  • If a vaccinated healthcare personnel is symptomatic and had unprotected exposure to COVID-19 in the past 14 days, they should be excluded from the workplace, evaluated for COVID-19 and CDC guidance should be followed.

Under recent CDC guidance, vaccinated healthcare personnel with an exposure to someone with suspected or confirmed COVID-19 may return to work if they meet all of the following criteria:

  • Are fully vaccinated (i.e., more than two weeks following receipt of the second dose in a 2-dose series, or more than two weeks following receipt of one dose of a single-dose vaccine).
  • Are within 3 months following receipt of the last dose in the series.
  • Have remained asymptomatic since the current COVID-19 exposure.

The CDC reminds healthcare employers to:

  • Educate employees about the potential for short-term systemic signs and symptoms post-vaccination to assist in identifying symptoms that may be vaccination related versus those that are not.
  • Create mechanisms for timely assessments of vaccinated employees to distinguish between circumstances warranting exclusion from work from situations where providers can safely return.
  • Consider nonpunitive sick leave options to encourage reporting of symptoms.

This guidance may evolve as we continue to learn more about the effects of vaccination, but is a helpful tool for healthcare employers looking to ensure adequate staffing coverage while confirming an employee’s return to work is done in a safe manner.  Jackson Lewis continues to monitor the unique issues affecting healthcare employers in a post-vaccinated world.  Please reach out to the Jackson Lewis attorney with whom you regularly work, or any member of our COVID-19 team to learn more.

*This post was updated 2/12/2021 to include CDC guidance issued 2/10/2021, after the initial post publication.