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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 operation
1. 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 identified
7.
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 guidance
8. 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.