Clarifying Recent Guidance on Contact Tracing and Close Contacts

August 25, 2021 • Amy Campbell

Clarifying Recent Guidance on Contact Tracing and Close Contacts

Districts have some confusion about recently updated public health guidance from the Texas Education Agency (TEA), which points to guidance from the Centers for Disease Control (CDC) and the Texas Department of State Health Services (DSHS).

The following summary of TEA, CDC, and DSHS guidance is intended to clarify what districts are required or expected to do related to COVID-19 exposures and positive cases. Guidance from TEA, CDC, and DSHS continues to evolve, so it should be noted that this guidance is effective as of September 2. This post will be updated with changes or additions to the guidance as needed to reflect the most current information.

Positive cases and contact tracing

If an individual with a test-confirmed case has been in a school, a school must do the following:

  • Notify its local health department.
  • Submit a report to DSHS via their online form, with submission required each Monday for the prior seven days.
  • Notify all teachers, staff, and families of all students in a classroom or extracurricular or after-school program cohort if a case is identified among students, teachers, or staff who participated in those classrooms or cohorts.

TEA’s public health guidance clarifies districts aren’t required to conduct contact tracing, though local health authorities may investigate cases that occur in a district. If a district is made aware of a positive case, either through self-reporting or by the local health authority, the district must engage in the notification and reporting requirements outlined above.

Close contacts

The CDC definition of close contact has changed over the past year as more is learned about the virus and vaccines. Currently, a close contact is someone who was within six feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period.

There is an exception to the definition of close contact for students in a K-12 indoor classroom setting who were within three to six feet of an infected student if both the infected student and the exposed student correctly and consistently wore well-fitting masks the entire time.

According to CDC guidance, people who have been in close contact with someone who has COVID-19 should quarantine. Notably, the CDC states that the following close contacts with recent exposure may NOT need to quarantine:

  • People who have been fully vaccinated
  • People who were previously diagnosed with COVID-19 within the last three months

By this definition, vaccinated staff or those who recently tested positive for COVID-19 are not immediately required to quarantine unless they display symptoms of the illness. The CDC guidance says vaccinated individuals who are exposed should get tested three to five days after exposure and wear a mask indoors in public for 14 days following exposure or until they receive a negative test result.

Staff who are not fully vaccinated who meet the close contact threshold are recommended by the CDC to quarantine and by TEA to remain off campus, so it’s safest for districts to require staff who are not fully vaccinated who meet the definition of close contact to take leave during the quarantine period.

But, remember, fully vaccinated staff who are not displaying symptoms are not required to quarantine. However, the public health guidance states that if a district chooses to allow a close contact to return to work, TEA requires rapid testing be performed periodically until the end of day 10 after exposure, whether the individual is vaccinated or not. This differs from guidance from the CDC for vaccinated close contacts.

TEA’s public health guidance says districts must exclude staff who are actively sick with COVID-19 or have a positive test result, and return is contingent upon staff meeting reentry conditions set out in DSHS rule. Reentry conditions include:

  • If symptomatic, at least 10 days must have passed since symptom onset, fever-free for 24 hours without the use of fever-suppressing medications, and other symptoms have improved.
  • If positive for COVID-19 but no symptoms, at least 10 days must have passed after the day they were tested.

These same reentry conditions apply to students who test positive, have symptoms of COVID-19, or are excluded because of household-based close contact.

Amy Campbell is director at TASB HR Services. Send Amy an email at

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Tagged: COVID-19, "Epidemic Response"