US | COVID-19 | CDC Issues Testing Strategy Guidance for Workplaces

On July 3, 2020, the US Centers for Disease Control and Prevention (CDC) issued new guidance titled “SARS- CoV-2 Testing Strategy: Considerations for Non-Healthcare Workplaces.” The purpose of the guidance is to help employers determine when and how to test employees.

The guidance provides guidance and strategies for SARS-CoV-2 viral testing for five categories of people:

  1. Individuals with signs or symptoms consistent with COVID-19
  2. Asymptomatic individuals with recent known or suspected exposure to SARS-CoV-2 to control transmission
  3. Asymptomatic individuals without known or suspected exposure to SARS-CoV-2 for early identification in special settings
  4. Testing to determine resolution of infection
  5. Public health surveillance

Individuals with Signs or Symptoms Consistent with COVID-19

  • Employers may consider conducting daily in-person or virtual health checks to identify symptoms consistent with COVID-19 before they enter a facility.
  • Workers with COVID-19 symptoms should be immediately separated from other employees, customers, and visitors, and sent home or to a healthcare facility.
  • If an employee tests positive, the employee should not come to work and should isolate at home until the employee satisfies the CDC’s criteria for discontinuing home isolation.

Testing Asymptomatic Individuals with Recent Known or Suspected Exposure

  • CDC recommends viral testing for all close contacts of person with COVID-19. This is particularly important in work settings where employees have close contact with each other.
  • CDC encourages employers to consult with state, local, territorial, and tribal health departments to help inform decision-making about broad-based testing.
  • Care should be taken to inform employees who have possible exposure to COVID-19 while maintaining the confidentiality of the individual with COVID-19 as required by the Americans with Disabilities Act (ADA).

Testing Asymptomatic Individuals Without Known or Suspected Exposure for Early Identification in Special Settings

  • Viral testing of workers without symptoms may be useful to detect COVID-19 early and stop transmission quickly, particularly in areas with moderate to substantial community transmission.
  • This is particularly useful in workplaces where physical distancing is difficult to maintain or where medical evaluation or treatment might be delayed due to their remoteness.
  • Approaches may include initial testing of all workers before entering a workplace, periodic testing of workers at regular intervals, and/or targeted testing of new workers or those returning from a prolonged absence.

Testing to Determine Resolution of Infection

  • The decision to discontinue home isolation and return to work for employees with suspected or confirmed COVID-19 should be made in the context of local circumstances.
  • Options include a symptom-based, time based, or a test-based strategy.
  • The determination of which strategy to use should be made in consultation with healthcare providers and public health professionals.
  • Under the ADA employers are permitted to require healthcare provider’s note to verify that employees are healthy and able to return to work, however, healthcare provider offices and medical facilities may be extremely busy during the pandemic. In such cases employers should consider not requiring a healthcare provider’s note for employees who are sick to validate their illness, qualify for sick leave, or to return to work.

Public Health Surveillance for SARS-CoV-2

  • Testing is considered to be surveillance when conducted to detect transmission hot spots or to better understand disease trends in a workplace.
  • Occupational medicine surveillance programs may use testing to assess the burden of COVID-19 in the workforce, assess factors that place employees at risk for workplace acquisition of COVID-19 or evaluate the effectiveness of workplace infection control programs.

Surveillance should only be undertaken if the results have a reasonable likelihood of benefiting workers.

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Sources:

SARS-CoV-2 Testing Strategy: Considerations for Non-Healthcare Workplaces, CDC Guidance, July 3, 2020.

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