Jan. 13, 2021

The Centers for Disease Control and Prevention (CDC) has published a new order requiring pre-departure COVID-19 testing for all passengers arriving to the U.S. from international locations.

Starting Jan. 26, passengers must be tested no more than three days prior to their departure and must provide proof of the negative result or documentation of having recovered from COVID-19 to the aircraft operator.

“It’s important to note this order applies to all aircraft operators, including non-commercial aircraft operators,” said Brian Koester, CAM, director of flight operations and regulations. “NBAA previously requested the CDC and FAA provide alternate procedures for passengers departing countries with no COVID-19 testing capacity or documentation that doesn’t meet the CDC requirements for a Qualifying Test. The order published recently provides a waiver process for those scenarios and also outlines more detailed guidance on how to address passengers who have already recovered from COVID-19.”

The CDC defines an “aircraft operator” as “an individual or organization causing or authorizing the operation of an aircraft.”

All aircraft operators – including business and general aviation operators – must confirm the following for all passengers:

  • Documentation of a negative qualifying test result (passengers 2 or older)
  • Personal identifiers (e.g., name and date of birth) on the negative test result match the passenger’s passport or other travel documents
  • If the passenger is arriving on a direct flight to the U.S., the specimen was collected within three calendar days preceding the flight’s departure

  • If the passenger is arriving via one or more connecting flights, the specimen was collected within the three calendar days preceding the departure of the initial flight but only if:
    • The connecting flights were booked as a single passenger record with a destination in the U.S.
    • Each connection is no longer than 24 hours
    • The airline or aircraft operator has instructed the passenger to comply – and uses reasonable efforts to facilitate compliance – with the safety protocols set forth in Runway to Recovery 1.1, Dec. 21, 2020, during such connections
  • The test performed was a viral test
  • The test result states “Negative,” “SARS-CoV-2 RNA NOT DETECTED,” “SARS-CoV-2 ANTIGEN NOT DETECTED” or “COVID-19 NOT DETECTED.” A test marked “invalid” is not acceptable.

Alternatively, in the case of a passenger who has recovered from COVID-19, the operator must confirm the passenger has written or electronic documents of recovery, meaning:

  • The passenger has presented documentation of a positive test result and a signed letter on official letterhead that contains the name, address and phone number of a licensed healthcare provider or public health official stating that the passenger has been cleared for travel
  • The positive test result occurred within the last three months preceding the passenger’s flight to the U.S., or at such other intervals as specified in guidance
  • Personal identifiers (e.g., name and date of birth) on the positive test result match the passenger’s passport or other travel documents; and
  • The test result states “POSITIVE,” “SARS-CoV-2 RNA DETECTED,” “SARS-CoV-2 ANTIGEN DETECTED” or “COVID-19 DETECTED.” A test marked “invalid” is not acceptable.

Aircraft operators may not board any passenger without the verifying attestation and confirming the documentation as described above, minus the following exemptions:

  • Crewmembers provided that they follow standard protocols for prevention of COVID-19 as set forth in relevant FAA guidance, including Safety Alerts for Operators (SAFOs)
  • Operators transporting passengers with COVID-19 pursuant to CDC authorization and in accordance with CDC guidance
  • Federal law enforcement personnel while on official duty, including U.S. military
  • Operators granted specific waivers from the application in the order based on the CDC’s determination that a foreign country lacks available SARS-CoV-2 testing capacity.

Aircraft operators are required to retain documentation related to this order for two years.

Aircraft operators should review the CDC Order and FAQs for more information, including what constitutes a valid test, then provide appropriate guidance to crewmembers, dispatchers or other personnel tasked with the above confirmation activities.

Review the CDC order and FAQs.