We have a routine periodic COVID testing program for our health care employees and providers. Those who have been vaccinated will continue to test. What about those with PCR proven COVID who have returned to work? Due to the number of false positives, I was asked to put in a policy: We will not test those back with COVID and RTW for the first 90 days after they return.

Current CMS regulations require that long term care facilities conduct routine surveillance testing for COVID-19 in healthcare personnel (HCP) and residents, with a frequency determined by the test positivity rate in the facility’s county of operation1. Other facilities may choose to conduct periodic screening, although there is no regulatory requirement to do so at this time. 

Upon diagnosis of a new COVID-19 infection, HCP should be excluded from the workplace until criteria for return to work are met, typically 10 days from the onset of symptoms with resolution of fever and improvement in symptoms. Repeat viral tests are not recommended for return to work2. Prolonged PCR positivity is well-documented following initial infection3,4 and does not indicate infectivity5,6. In the absence of symptoms, the Centers for Disease Control and Prevention recommend against viral tests (PCR or antigen tests) for 90 days following the initial infection. Testing could be performed for evaluation of COVID-19-like symptoms 45 or more days following the initial infection if risk factors for new disease acquisition are identified7.

Given that viral tests may be positive for a prolonged period of time following infection, periodic screening programs should incorporate a testing hiatus for HCP who develop COVID-19 infection. An employer would be violating EEOC requirements if they restricted an employee from working based upon COVID-19 testing that is not consistent with CDC guidance8. A reasonable policy would be to suspend asymptomatic testing for 90 days after infection, with a clinical evaluation and consideration of testing if the employee developed new symptoms 45 days or more following infection.


  1. Centers for Medicare & Medicaid Services.  Interim Final Rule (IFC), CMS-3401-IFC, Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency related to Long-Term Care (LTC) Facility Testing Requirements and Revised COVID-19 Focused Survey Tool, August 26, 2020. Available at https://www.cms.gov/files/document/qso-20-38-nh.pdf  Accessed January 24, 2021.
  2. Centers for Disease Control and Prevention. Criteria for Return to Work for Healthcare Personnel with SARS-CoV-2 Infection (Interim Guidance). August 10, 2020. Available at https://www.cdc.gov/coronavirus/2019-ncov/hcp/return-to-work.html Retrieved January 24, 2021.
  3. Korea Centers for Disease Control and Prevention. Findings from Investigation and Analysis of re-positive cases. May 19, 2020. Available at: https://www.cdc.go.kr/board/board.es?mid=a30402000000&bid=0030&act=view&list_no=367267&nPage=1external icon  
  4. Li N, Wang X, Lv T. Prolonged SARS-CoV-2 RNA Shedding: Not a Rare Phenomenon. J Med Virol 2020 Apr 29. doi: 10.1002/jmv.25952.
  5. Wölfel R, Corman VM, Guggemos W, Seilmaier M, Zange S, Müller MA, et al. (2020). Virological assessment of hospitalized patients with COVID-2019. Nature 2020 May;581(7809):465-469. doi:10.1038/s41586-020-2196-x
  6. Bullard J, Durst K, Funk D, Strong JE, Alexander D, Garnett L et al. Predicting Infectious SARS-CoV-2 From Diagnostic Samples. Clin Infect Dis 2020 May 22.  doi: 10.1093/cid/ciaa638.
  7. Centers for Disease Control and Prevention. Investigative Criteria for Suspected Cases of SARS-CoV-2 Reinfection, October 27, 2020. Available at https://www.cdc.gov/coronavirus/2019-ncov/php/invest-criteria.html#:~:text=Since%20August%202020%2C%20CDC%20has,Isolation%20and%20Precautions%20for%20Adults Accessed January 24, 2021.
  8. US Equal Employment Opportunity Commission. What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws. Available at https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws Accessed January 24, 2021.

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The Forum does not necessarily represent an official ACOEM position. The Forum is intended for health professionals and is not intended to provide medical or legal advice, including illness prevention, diagnosis or treatment, or regulatory compliance. Such advice should be obtained directly from a physician and/or attorney. Questions are answered with the best available data or recommendations at the time.