More CDC Guidance on Employee Testing

The CDC has issued guidance to provide non-healthcare employers with strategies for consideration of incorporating testing for COVID-19 into a workplace COVID-19 preparedness, response, and control plan. Of particular interest to employers is the CDC’s current position on testing to determine resolution of infection, i.e., requiring a negative test before an employee can return to work. Current CDC guidance says:

The decision to end home isolation and return to work for employees with suspected or confirmed SARS-CoV-2 infection should be made in the context of clinical and local circumstances. Polymerase chain reaction (PCR) amplification tests have detected SARS-CoV-2 RNA in some people’s respiratory samples after they have recovered from COVID-19. Prolonged viral shedding has been demonstrated without direct evidence for virus capable of replicating or causing infection. Consequently, in most cases, evidence supports a symptom-based strategy to determine when to discontinue home isolation or precautions. For persons who are severely immunocompromised, a test-based strategy could be considered in consultation with infectious diseases experts. For all others, a test-based strategy is no longer recommended except to discontinue isolation or precautions earlier than would occur under the symptom-based strategy.

The CDC guidance also addresses doctor’s notes for returning employees. The CDC acknowledges that, under the ADA, employers are permitted to require a healthcare provider’s note to verify that employees are healthy and able to return to work. But, CDC guidance suggests that doctor’s notes should not be required:

However, as a practical matter, employers should be aware that healthcare provider offices and medical facilities may be extremely busy during periods of community transmission of SARS-CoV-2 and may not be able to provide such documentation in a timely manner. 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. Most people with COVID-19 have 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.

More information is here:


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