Dr. Cohen:

Pan End It! is a nationwide group of disabled, ill, and immunocompromised individuals and allies working for continued COVID-19 protections. We and the undersigned organizations, experts, and concerned individuals are writing to express our extreme disapproval of the CDC's changes to the COVID-19 isolation guidelines and its new "Respiratory Virus Guidance". This guidance is dangerous, anti-science, anti-public health, discriminatory, and made without public comment.

SARS-CoV-2 is an airborne virus. It does not exist in a separate realm; it requires interaction with people and spaces they inhabit to continue spreading. COVID-19 continues to strongly impact people, and there is no long lasting immunity against infection. Using a symptoms-based approach does not work with a virus like SARS-CoV-2 where it's known to have a large number of people who are asymptomatic yet infectious. Most people remain infectious with COVID-19 for more than five days, whether symptoms are present or not, and a fever is not a good indicator of infectiousness. An isolation period of ten days, not significantly less as the CDC has arbitrarily decided, is scientifically needed.

The CDC's recent guidance change indicates that the CDC either doesn't recognize this, that COVID-19 is spread among people, or they are completely detached from the realities of the lives of people who are impacted by their decisions. The CDC seems to think people who are high-risk - or those who simply don't wish to catch a contagious disease that has killed millions and disabled millions more in the last 4 years - exist in self-contained bubbles separate from "normal" society; that we aren't complete people with families, partners, roommates, friends, neighbors, and strangers we interact with every day. We apparently aren't workers without sick pay constantly exposed to sick co-workers and customers. We aren't teachers and students in overcrowded and unventilated or underventilated classrooms. We aren't people providing care to loved ones. We aren't commuters crammed into buses and trains with no air filtration. We are not people living in congregate settings with caregivers and visitors, incarcerated individuals without access to PPE, or unhoused members of society who are often not able to isolate at all. The lack of consideration of the needs and realities of people living in these situations indicates that, to the CDC, we are not people at all.

Additionally, the CDC categorizing COVID-19 as a respiratory illness in the same category as cold and flu is either a misleading oversight or a deliberate attempt to downplay the actual nature and severity of COVID-19. SARS-CoV-2 is much more dangerous than the flu, and a BSL-3 pathogen cannot be treated the same way. COVID-19 can affect every organ system and may cause Long COVID, with increased risk after reinfections. The chance of developing Long COVID increases with each infection, as does the chance of severe outcomes from COVID-19 with each reinfection. Although the new respiratory guidance's background document says that Long COVID is declining, according to the Household Pulse Survey, it is actually increasing.[1] COVID-19 remains a leading cause of death, disease, disability, and school and workplace absence. Having COVID-19 can weaken your immune system - it does not strengthen it - and can lead to an increase in getting other illnesses more regularly. COVID-19 remains a very serious multi-systemic disease spread primarily though airborne pathways, and none of this has changed. The only thing that has changed is the CDC's complete capitulation to political and business interests to force people into working and going to school while sick and ignoring their own needs.

This new guidance does nothing to address the ongoing pandemic and the real problems people face when infected with COVID-19. The CDC claims this change is to better align with what people need and are currently doing, but it doesn't address the underlying issues for people's behavior. The CDC accurately notes that people are unable to stay home when sick, or that doing so puts livelihoods at risk, because they do not have paid sick leave and can't make money while staying home sick. They also recognize that people are less likely to test for and report COVID-19 infections out of this concern for having to stay home without paid leave. But none of these are reasons that are the results of people's need to rest and isolate while sick; they are the reality of living in a society that does not provide proper support to people - ever - but especially when they need to stay home and cannot work. Many people are not choosing to work while sick; they have no other choice. These new guidelines are incredibly shortsighted.

Although the decision to remove isolation guidelines for COVID-19 is presented as one that benefits workers who are unable to follow the 5-day isolation guideline due to lack of paid sick leave, it does nothing of the sort. Instead of following the science and advocating for better policies, the CDC is putting workers at further risk. The isolation change is not a reflection of COVID-19's impact on workers, which remains substantial, as people are experiencing multiple infections a year. The new guidance was proposed because it serves the interests of corporations that forces workers to work while sick, and to remove any remaining rights they may have to rest and recover. Currently, nothing is stopping workers who want to go to work while COVID-19 positive from doing so if they choose not to test and isolate. This guidance change from the CDC does not affect that reality. What will change is the ability of employees who do need to stay home and rest from doing so. The new guidance gives employers leverage to end COVID-19 sick leave and prevent employees from utilizing and remaining sick leave - even when they want to do so. Ultimately, this goes much farther than isolating or COVID-19; it is an attack on workers' rights to use their sick leave now and opens the opportunity for additional attacks on workers' rights and ability to advocate for paid sick leave in the future.

Another important consideration is the impact of COVID-19 on children and schools. Children are also impacted by COVID-19, and the new respiratory guidance will cause them harm. The CDC has shared that from January 2022 to July 2023, half the children who died from COVID-19 had no underlying health conditions.[2] Children of color are hospitalized and die at higher rates from COVID-19.[3] It is estimated that 16% of children develop Long COVID after an infection.[4] Additionally, conditions resulting from COVID-19 infections such as childhood diabetes are on the rise.[5] Household spread often comes from a child.[6] The inclusion of cleaning the air in the new guidance will be outweighed by the increased exposures in schools, which will lower attendance and cause more infections and harm of children and staff.

This isolation guidance is also discriminatory and against state and federal law. Under the ADA, disabled people have an equal right to access public spaces as nondisabled people; under Section 504, disabled students have the right to a Free Appropriate Public Education (FAPE). Several communities are at increased risk for severe outcomes from COVID-19, including people of color, older people, and other individuals who are at high-risk (a significant portion of the population). The CDC is aware that these communities are at increased risk. This new isolation guidance will cause repeated exposure to students, teachers, workers, and other disabled people accessing public spaces who will get severely ill or die. This means many disabled children can no longer go to their school. It means many disabled workers can no longer work because of the risk of exposure. This also ignores that there are people who may not able to avoid exposure if a person who is COVID-19-positive returns to work, like people who are incarcerated, live in congregate settings, or rely on caretakers.

It is concerning to us that the new guidance is written in vague language that leaves out or de-emphasizes many important points and needed guidance for COVID-19. Masking and testing to protect oneself - two of the most important tools that we have against COVID-19 and other diseases - are listed as "additional prevention strategies" rather than "core prevention strategies," but hygiene such as washing one's hands is included as a core strategy, which is not protective against COVID-19. The photograph on the masking page is also of a surgical mask, thus not modeling an N95 as more protective.

In the new guidance, the CDC does not tell people to mask if they are COVID-positive or feeling sick - or even strongly recommend it - but instead lists masking as the third item presented in an either/or list, thus downplaying it as an essential tool to make public spaces accessible. In addition, the high-risk groups list appears narrowed and doesn't include other groups at heightened risk, including people of color; the CDC's main People with Certain Medical Conditions page has also not been migrated over, which is an important page many people access to learn about their own risk and use for documentation of being high-risk. There is also concern about other COVID-19-specific pages being marked as no longer up-to-date, when COVID-19-specific information is still needed for people to stay safe.

The continued chipping away of guidelines continues to reduce people's abilities to keep themselves safe now and in the future. What will we do when COVID levels reach or exceed previous surge wastewater levels again? What will be do when we need paid sick leave? What will we do when the next pandemic hits? The CDC must provide leadership with public health guidelines that reflect the path that we should be taking, not the path that has been forced upon us for the sake of convenience. The CDC should not make recommendations that make people sicker.

The consequences of health outcomes from COVID-19 will affect citizens, health policies, and resources for years to come. The CDC is shirking their responsibility to public health and equal rights under the law. The CDC must rescind these new guidelines and address that the lack of paid sick leave in the United States is a public health emergency by working with other agencies in support of universal paid sick leave. The CDC should emphasize in updated guidance that masking and testing are core prevention strategies. More specific information on groups and individuals who are high-risk needs to be added to future guidelines, and the CDC high-risk conditions page retained. The CDC must cease capitulating to business interests and political pressure and recommend scientifically-based isolation guidance in order to protect people and reduce the burden of COVID-19.

Citations

1. Centers for Disease Control and Prevention. (2024, February 23). Long COVID - Household Pulse Survey. https://www.cdc.gov/nchs/covid19/pulse/long-covid.htm

2. Evidence to recommendations framework. (n.d.). https://www.cdc.gov/vaccines/acip/meetings/downloads/slides-2023-09-12/11-COVID-Wallace-508.pdf

3. Two-year study finds black children with Covid-19 had twice as many deaths as white children with the virus. Morehouse School of Medicine. (n.d.). https://www.msm.edu/RSSFeedArticles/2023/March/2022BCAC_Report.php

4. A Systematic Review of Persistent Clinical Features After SARS-CoV-2 in the Pediatric Population . American Academy of Pediatrics. (n.d.). https://publications.aap.org/pediatrics/article/152/2/e2022060351/192816/A-Systematic-Review-of-Persistent-Clinical

5. Children's Health. (n.d.). COVID-19 and diabetes in children. https://www.childrens.com/health-wellness/can-covid-19-cause-diabetes-in-children

6. More than 70% of us household COVID spread started with a child, study suggests. CIDRAP. (n.d.). https://www.cidrap.umn.edu/covid-19/more-70-us-household-covid-spread-started-child-study-suggests