CDC AND AIRLINES TO INITIATE CONTACT TRACING PROGRAM FOR PASSENGERS TRAVELING TO U.S.

March 1, 2021

On February 19, 2021, Airlines for America announced that its member airlines voluntarily agreed to collect contact tracing data from passengers traveling into the United States and transmitting that data to the Centers for Disease Control (CDC).  Under the agreement, U.S. airlines will ask passengers to provide two phone numbers, email addresses, and an address of where the travelers will be staying in the U.S.  In the event there was a possible COVID-19 exposure on an aircraft, the information submitted by airlines will assist CDC in conducting contact tracing with local health authorities.  The airlines and CDC met on February 25, 2021 to further discuss plans for the program, and CDC is likely to issue an order in approximately 10 days.  Tentatively, the airlines and CDC have agreed to the following:

  • Implementation of contact tracing will begin 90-100 days after the issuance of a CDC Order;

  • CDC would prefer airline DCS not to issue a boarding pass without the passenger completing the required data elements (rather than a board/no board process);

  • APIS and JSON are acceptable; PNR.GOV will be acceptable in the short term;

  • Passengers will not be required to attest to the information, and airlines will not be responsible for validation of the information; and

  • Airlines will not be required to store the contact tracing information.

If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Andy Orr (aorr@eckertsemans.com or 202-659-6625).

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Authors

Evelyn D. Sahr Photo Washington, D.C.

Evelyn D. Sahr

Member - Washington, D.C.

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Drew M. Derco Photo Washington, D.C.

Drew M. Derco

Member - Washington, D.C.

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Andrew P. Orr Photo Washington, D.C.

Andrew P. Orr

Member - Washington, D.C.

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