Interpreting CDC Mask Guidance for Your Organization

Last week, the CDC updated its guidance to allow fully vaccinated people to “resume activities that [they] did prior to the pandemic, without wearing a mask or physically distancing.” This is a cause for celebration, and a relief for many of us. Yet we must also recognize that today, there are still more than 204 million Americans not yet vaccinated, including all children under 12 years old

This change in guidance came fast, and you may have already made decisions on how to respond. However, having reviewed both the guidance and the latest vaccination rates, we wanted to share our perspective with you.

Safety is an inherent part of your mission. As you know, you are called to protect all individuals in your care—especially vulnerable populations. This includes those not yet vaccinated, unable to be vaccinated, or those who choose not to be vaccinated. As the CDC guidance changes, the core reasoning behind your actions doesn’t change—safety, kindness and equitable communities come first. Here’s what that means to us:

Wearing Masks: Redwoods’ Guidance
Science supports that masks provide an effective control measure against infections, and we encourage mask wearing in all indoor locations unless we can establish that individuals are fully vaccinated. Specifically in relation to vaccinated and unvaccinated individuals, there are two viable ways to interpret the CDC guidance:

  1. Continue to require masks for all indoor activities and communicate why to your community. While there will no doubt be some push back, we believe the core goal of protecting the most vulnerable is something most of your members and guests will share.
  2. Allow vaccinated people to go maskless but ask specifically about vaccine status upon entering your facility. By asking all members and guests, it gives you the opportunity to inform everyone of your mask requirements.

There are still a lot of other questions out there, here’s our response:

Can I Ask if Someone’s Vaccinated?
Asking anyone that enters your facility if they are vaccinated is not a HIPAA violation. “HIPAA, is a law that prevents health care professionals from sharing private health information without the patient’s permission,” writes USA Today. “The law has no bearing on who can ask or answer questions about health status outside of a healthcare setting.”

In your organization, you are legally allowed to ask any person about their vaccine status. If you are going to allow maskless entry, we recommend asking everyone entering the building to disclose their vaccine status. We have created a sample script for you to share with your staff to make these conversations easier.

Should I Require Staff to be Vaccinated?
Making sure that staff are vaccinated is an important priority. Whether or not you are requiring staff vaccinations (we are requiring vaccines for all of our employees planning to work in the office), we recommend an active program of education and support for staff vaccinations. Last month, we held a webinar specifically focused on employee safety this summer, and discussed all of the considerations you should take into account when it relates to staff vaccinations. Please watch our recording to hear more about our guidance and considerations.

How Should I Respond to Negative Reactions?
We know, of course, that any change in CDC guidance creates uncertainty, and it creates questions. It can also influence the attitudes and expectations of the communities you serve, sometimes negatively. A small business in our own community experienced this, saying, “People (were) trolling my business page leaving fake/false reviews, making claims I’m a Nazi and stuff like that.” The negativity came from the business’ requirement for all to wear masks. You can also find a sample script for staff to use if a member or guest pushes back on your organization’s policy.

How Does This Guidance Affect Camp and Other Youth Summer Programs?
While the majority of youth are not able to be vaccinated (all children under 12), most of the previous protocols will continue to apply to those programs. We are expecting specific guidance on summer camps to be released from the CDC shortly. When that becomes available, we will share with you. Until then, the ACA Field Guide on Implementation of CDC Guidance continues to be the best resource for camps to use.

Should I Continue to Use Liability Waivers and Signs?
The risk of COVID-related liability issues, if an infection is traced to your facility, continues to be somewhat unclear. However, given that the current legal environment trends toward plaintiff-friendly, we continue to recommend both caution in COVID protocols, and ongoing use of prominent signage and waivers that communicate the ongoing risk of infection. You may download sample waivers and signage on our website. This is especially important if you plan to allow maskless entry.

We know this will be challenging. And we know that you will approach this, as you always do, by putting mission and values first—at the heart of your decision-making and your communications.

Please reach out to your Redwoods Consultant if you have any questions, concerns, comments or experiences to share. We want to hear how this is going on the ground—and we stand ready to support you in any way we can.