The U.S. Centers for Disease Control and Prevention (CDC) has issued on July 3 a new guidance intended to help employers to properly determine when testing in non–health care workplaces is appropriate, emphasizing the importance of having a coherent testing strategy and an effective response plan.
The guidance, however, is subject to change and should be implemented as a supplement to state or local public health provisions or direction from the Equal Employment Opportunity Commission (EEOC).
These are the 5 testing scenarios that employers may adopt:
This is the most relevant situation—typified by identifying symptoms during daily screening before employees are allowed into the workplace. The guidance recommends immediately isolating any employee who exhibits related symptoms and sending them home or to a health care facility, depending on the severity of their symptoms.
A positive result should keep the employee isolated at home until subsequent testing indicates they meet the CDC’s criteria for discontinuing home isolation.
Any employees who may have been exposed to this employee should also be isolated and tested.
Any employee who has been within 6 feet of an infected individual for at least 15 minutes should be immediately quarantined and tested. However, because the virus might not be detected immediately after exposure, the CDC says it’s best to wait several days after exposure before testing, with the employee remaining quarantine at least until the test results are available.
In this scenario, state or local public health authorities normally either initiate the testing, or are consulted for guidance.
This mass testing approach may be appropriate in high-transmission and close-contact areas in order to identify asymptomatic infected employees who are not suspected or known to have been exposed to the virus.
High-risk non–health care work settings include the following:
The CDC encourages employers to devise a strategic plan for modifying their operations based on the number of infected employees as well as managing “a higher risk of false positive results in a low prevalence population.”
Employers may also ask employees to undergo daily screening prior to entering the workplace and recurring tests at regular intervals, as well as conduct targeted testing of new workers or those returning from a long absence.
Employers may require recovered employees to undergo testing before returning to work, although the CDC concedes that traces of the virus may still be detected post-recovery.
The agency prefers a time-based approach to ending quarantine (e.g., 14 days from exposure, over a testing requirement); and it should be noted that most infected individuals have only a mild illness, “can recover at home without medical care, and can follow CDC recommendations to determine when to discontinue home isolation and return to work.”
In this scenario, COVID-19 testing may be used for the purpose of public health surveillance—for detection of high-transmission areas or for improved understanding of disease trends in a workplace.
This being more often a public health function, employers should implement testing only “if the results have a reasonable likelihood of benefiting workers.”
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This article provides general information and shouldn’t be construed as legal or HR advice. Since employment laws may change over time and can vary by location and industry, please consult a lawyer or HR expert for advice specific to your business. You can also contact Payroll Systems to inquire about our HR support services.