Quirky Quarantine Quandary: The New Changes to Connecticut’s Travel Advisory That May Leave Employers with More Questions Than Answers

[The following is an update to our recent blog post addressing how Connecticut’s decision to impose a quarantine on certain travelers entering the state creates challenges for employers in administering FFCRA leaves.]

On July 21, 2020, Governor Lamont signed Executive Order 7III, strengthening the travel advisory he issued on June 24. The new order modifies the advisory to require (rather than merely recommend) travelers who enter Connecticut from states with a daily positive COVID-19 test rate higher than 10 per 100,000 residents, or a seven-day rolling average test positivity rate above 10%, to self-quarantine for 14 days. Although the original travel advisory did not describe an enforcement mechanism, the new version has teeth -- the $1,000 penalty kind. 

As part of the revision, Governor Lamont also updated the list of “hot spot” states meeting the Executive Order’s criteria. As of August 4, the order subjects travelers from 34 states (plus Puerto Rico) to a 14-day quarantine, including: Alaska, Alabama, Arkansas, Arizona, California, Florida, Georgia, Iowa, Idaho, Illinois, Indiana, Kansas, Kentucky, Louisiana, Maryland, Minnesota, Missouri, Mississippi, Montana, North Carolina, North Dakota, Nebraska, New Mexico, Nevada, Ohio, Oklahoma, Rhode Island, South Carolina, Tennessee, Texas, Utah, Virginia, Washington, and Wisconsin. Importantly, the mandatory quarantine applies to Connecticut residents returning from the listed states, as well as to residents of those states who are visiting Connecticut.

The amended order also provides a testing option to accommodate individuals who are “unable to self-quarantine,” although that term is not defined. The quarantine requirement does not apply to an individual who has “had a negative test result for COVID-19 in the 72 hours prior to arriving in Connecticut and provides written proof to the Commissioner or her designee of such a result.” Although the 72-hour test protocol was introduced in the initial order, providing a written statement of proof to the Commissioner is a new requirement. If a traveler obtains a test in the 72 hours prior to travel but the result is still pending upon arrival in Connecticut, he or she must self-quarantine until the result is received and the written proof is submitted as described above. We expect to see additional guidance clarifying what makes someone “unable to self-quarantine,” as well as more details about the written proof requirement, in the coming days.

Travelers who have spent 24 hours or longer in a hot spot state within 14 days before arriving in Connecticut, and who are staying in Connecticut for more than 24 hours, are also required to complete a new Travel Health Form. These requirements will be “communicated widely at all major points of entry into Connecticut, including on highway message boards and Connecticut airports.”

Certain “essential workers” traveling from high-risk states to Connecticut are also exempt from quarantining under the order. Individuals “who work in critical infrastructure as designated by the Cybersecurity and Infrastructure Security Agency, including students in exempt health care professions, are exempted from the self-quarantine requirement when such travel is related to their work in Connecticut. This includes any state, local, and federal officials and employees traveling in their official capacities on government business. If such worker was in an Affected State for a reason other than Connecticut-related work (e.g., vacation), such worker shall self-quarantine and complete the Travel Health Form” as described above.

Employers should act quickly to notify employees of the requirements of the Governor’s revised order, including the requirement to quarantine for 14 days upon returning to Connecticut. We also recommend developing and implementing an Out of State Travel Policy outlining the protocols employees must follow prior to and after traveling, and modifying existing company policies (such as vacation or paid time off) as necessary.

Pullman & Comley has policy templates and other useful resources available to aid employers in navigating the confusing web of executive orders, laws, regulations, and other guidance related to COVID-19. If your organization is unsure about its obligations under the FFCRA or other COVID-19 guidance, please contact any of our Labor and Employment Law attorneys for assistance.

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