On Jan. 12, 2021, the U.S. CDC issued a new order requiring proof of a negative viral COVID-19 test (NAAT/PCR or antigen), or medical proof of recovery, for anyone arriving from a foreign country to the U.S. The order goes into effect Jan. 26, 2021 for ALL flights, including private flight and GA aircraft.

Key points:

• Only ACTIVE crew members are EXEMPT. See FAQs for clarification on how exactly the CDC defines ACTIVE CREW.
• Passengers must show aircraft operator proof of negative result, taken with 3 days of boarding, or of recovery prior to boarding.
• Operators of private flights and general aviation must maintain passenger Attestations (i.e., declaration forms) for 2 years. Note: While the operator needs to see the test result, only the Attestations (which can be captured digitally) must be kept on file.
• The CDC’s website has more information on the order, including the official announcement and FAQs.

We will continue to update this article as new information and best practice recommendations are known.

CDC Testing Requirement FAQs

Here are some of the questions, we’ve received so far. The CDC FAQs also have additional information.

Testing, Exemptions, & Overseas options

• What kind of test is required? I don’t see PCR listed in the CDC FAQs.
  • CDC recommends that you get tested with a viral test (NAAT or antigen) 1-3 days before you travel internationally. PCR is a Type of Nucleic Acid Amplification Test (NAAt). You can learn more about the different types of tests here: https://www.fda.gov/consumers/consumer-updates/coronavirus-disease-2019-testing-basics.
• What is a verifiable test result?
  • A verifiable test result must be in the form of written documentation (paper or electronic copy) of a laboratory test result. Testing must be performed using a viral test (NAAT or antigen), and negative results must be presented to the airline prior to boarding. The test result documentation must include information that identifies the person, a specimen collection date and the type of test. A negative test result must show test was done within the 3 days before the flight. A positive test result must show the test was done within the 3 months before the flight
• Does having a COVID vaccine exempt one from the testing requirement?
  • No. The CDC’s FAQs state that everyone entering the U.S., including those who have been vaccinated, must provide either a negative test result or medical proof of recovery.
• Are home test results acceptable?
  • Per the CDC: The Order requires a lab report to be presented to the airline or to public health officials upon request. A home specimen collection kit that is tested in a laboratory should meet the requirements, if such methods have been approved by the country’s national health authorities.
• Does Universal or any other handler/third party vendor currently offer testing for crew and passengers at overseas locations?
  • Several of our FBOs and locations have relationships with testing providers inside the airport or at a medical facility. Contact us for a specific location.
• Are there any CDC exemptions if I’m returning from a country that does not have available testing?
  • Airlines or other aircraft operators may be granted specific waivers from the application of this Order based on CDC’s determination that a foreign country lacks available SARS-CoV-2 testing capacity. Such waivers may be granted based on a specific request made by an airline or aircraft operator to the CDC and will be limited to 14 days unless renewed by CDC.
• What if you get tested in the U.S. and are gone for less than 72 hours. Will that test be acceptable or do you need one from the country you visit? What if you plan to return the same day (quick trip to the Caribbean/Mexico, etc.?)
  • You will still need a test if your trip is shorter than 3 days. A viral test done in the US can be used to fulfill the requirements of the Order as long as the specimen was taken no more than 3 days before your return flight departs.  If your return travel is delayed longer than 3 days after your test, you will need to be retested before your return flight.
• What if I recently recovered from COVID-19?
  • CDC does not recommend getting tested again in the three months after a positive viral test, as long as you do not have symptoms of COVID-19. If you have had a positive viral test in the past 3 months, and you have met the criteria to end isolation, you may travel instead with documentation of your positive viral test results and a letter from your healthcare provider or a public health official that states you have been cleared for travel. The positive test result and letter together are referred to as “documentation of recovery.
• What happens if U.S. pax gets sick abroad? Can they return home to the U.S.?
  • In our interpretation of the order, you cannot return as a normal flight. You would either have to stay there until you recover or come home on an air ambulance flight. The CDC has provided interim guidance for transporting individuals with COVID exposure into the U.S.
• Tests are unreliable where I’m located. Can I be tested on arrival?
  • The testing requirements are pre-departure. Obtaining a test on arrival is not an option.
• On a tech stop in the U.S. are test/attestations required if pax/crew are not disembarking?
  • Yes, even tech stops require the attestation and a viral test, as the U.S. doesn’t have a distinction on that level but as seen as a stop in the country (ex. even customs would need to be cleared for a tech stop).

Quarantine

• Will I have to quarantine upon entering the U.S.? If so, how long?
  • Even before the current testing order went into effect, the CDC had the below recommended guidelines for testing and quarantine upon entering the U.S. Per a CDC spokesperson, the guidelines for quarantine are “not a mandatory quarantine, just a recommendation,” in an email to The Washington Post. The agency agreed that it will not be mobilizing in any way to enforce its guidance as a rule, and stated “there is not a mandatory, federal quarantine.”
  • Current CDC guidelines state the following:
    • Get tested 3-5 days after travel AND stay home to self-quarantine for 7 days after travel.
    • Even if you test negative, stay home to self-quarantine for the full 7 days.
    • If your test is positive, isolate yourself to protect others from getting infected.
    • If you don’t get tested, it’s safest to stay home to self-quarantine for 10 days after travel.
    • Avoid being around people who are at increased risk for severe illness for 14 days, whether you get tested or not.

Enforcement & record keeping

• What is the difference between attestation and testing?
  • For the Operator record retention requirement, it’s important to know the difference between the Attestation (i.e. A Declaration Form) and proof of a negative viral test results.
  • From CDC Fact Page: Do airlines and operators of private flights or general aviation aircraft need to keep copies of passenger test results? No, passengers must show a copy of their test results to airline employees or the aircraft operator before boarding, but the airline or aircraft operator does not need to retain copies of test results.
  • What should airlines and operators of private flights or general aviation aircraft do with passenger attestations? Operators of private flights and general aviation aircraft must maintain passenger attestations for two years, per the Order.
• Who is enforcing this and checking test results on arrival?
  • We’re still working to get more details on enforcement, but we have confirmed it will not be U.S. Customs and Border Protection. CBP informed us it plays no role in the implementation, monitoring, or enforcement of these latest CDC restrictions. Not adhering to the order, however, could result in government fines, so it’s important to maintain all documentation for two years, as stated in the order.
• Do airlines and operators of private flights or general aviation aircraft need to keep copies of passenger test results?
  • No, passengers must show a copy of their test results to airline employees or the aircraft operator before boarding, but the airline or aircraft operator does not need to retain copies of test results.
• Do passengers also need to have a copy of their attestation as well as the airline retaining it?
  • Passengers are only required to retain a paper or electronic copy of their negative test result or documentation of recovery for the entirety of their itinerary. The attestation should be submitted to and retained by the airline or aircraft operator.
• Universal to provide customers attestation template at no charge for all inbound U.S. Customs confirmations
  • Universal is providing a US CDC Attestation template as a DIY tool to help improve operational flexibility and manage risk for operators.  Ensuring each passenger has an attestation will be a stressful and new procedure for operators.  This is another tool in their toolbox, especially in short notice scenario, to help operators complete their missions safely and in compliance with regulation.  Note:  Solely for operators’ use, no need to return to Universal.

Crew exemptions

• Are crew members exempt?
  • According to the CDC’s FAQs: “Crew members on official duty, whether working or in an assigned deadhead status (transportation of a flight crew member as a passenger or non-operating flight crew member), are exempt from the testing requirement as long as they follow industry standard protocols for the prevention of COVID-19 as set forth in relevant Safety Alerts for Operators (SAFOs) issued by the Federal Aviation Administration (FAA).”
• What is the CDC’s definition of “active crew?”
  • Crew members on official duty assigned by the air carrier or operator that involves operation of aircraft, or the positioning of crew not operating the aircraft (i.e., on “deadhead” status), are exempt from the requirements of the Order provided their assignment is under an air carrier’s or operator’s occupational health and safety program. For the exemption to apply, the occupational health and safety program must follow industry standard protocols for the prevention of COVID-19 as set forth in relevant Safety Alerts for Operators (SAFOs) issued jointly by the Federal Aviation Administration (FAA) and CDC. Other persons, such as maintenance personnel or contractors, may also be exempted if:
    1. Their travel is for the purpose of operating the aircraft or ensuring the safety of flight operations; AND
    2. The air carrier extends its occupational health and safety program to cover these individuals and ensures these persons follow the protocols contained in SAFO and CDC guidance; AND
    3. The travel cannot be planned with sufficient time to enable the employee to take a COVID-19 test and obtain the results before the operational travel.
• If you are crew and out of the country for several days waiting on passengers, are you still considered on-duty and exempt?
  • If you are part of the active crew on a trip, most countries view you as on-duty thereby exempting you from testing and quarantine requirements. There are some exceptions to this rule so it’s best to always check in advance for your particular destination. For the U.S., please refer to the crew exemptions referenced above.
• If crew members are deadheading on an airline are they exempt?
  • Per the order, they would be considered active crew, however, for all practical purposes, they would have to provide a negative test to the airline.

Air ambulance and medical flights

• How does the CDC testing order impact medical and air ambulance flights? Can COVID patients still be transported?
  • Still researching.

Miscellaneous

• Will Universal be providing these COVID ops requirements as part of the trips your managing for us?
  • For each potential mission with Universal, you will receive the latest information as it pertains to COVID requirements to assist you in preparing for your trip.
• Any information on IATA developing a universally accepted “virtual COVID passport” that would be accepted by member nations as an official means of tracking testing compliance and/or vaccination proof?
  • Still researching.

Useful Links

• CDC Testing Order
• CDC FAQs
• NBAA CDC FAQs
• CDC Attestation
• CDC Interim Guidance for transporting individuals with COVID exposure
• CDC Country Specific Info