What U.S. Employers Should Know About COVID-19 Testing – Part 1

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The marketplace is flooded with information on COVD-19 testing; however, much of that information is technical in nature and difficult to understand. As HireRight’s Chief Medical Officer, I receive a lot of questions from employers about testing. What are the various testing methodologies available in the current market? When can employers conduct testing? How should testing be done? I am going to be covering these specific questions and much more in this two-part blog series.

Reopening Considerations
As businesses begin to reopen across the country from the imposed shutdown caused by the global coronavirus pandemic, employers are going to need to be vigilant, flexible and innovative in their approach to minimize the spread of the virus in their workplace and to safeguard their employees, customers, vendors and volunteers.

It takes a multi-faceted safety strategy to accomplish this, and organizations must include the following components as a baseline:

  • Conduct an assessment of your workforce – Employers should conduct a risk assessment of their worksites. For further help on this, review the Guidance on Preparing Workplaces for COVID-19 provided by OSHA.
  • Develop a policy governing how employees will return to the jobsite – Employers may want to assess their workforce needs and general health to determine an effective plan for safely returning everyone to physical work locations.
  • Evaluate your physical working environment – Adjustments may need to be made to open-floor plans by implementing protective shield barriers between desks or changing layouts and spacing in common areas. Personal protective equipment like masks should be required.
  • Develop safety protocols – The CDC has published guidance to assist employers with proper cleaning recommendations. EPA-approved disinfectants are an important part of reducing the risk of exposure to COVID-19.
  • Communicate, educate and train employees – A strong communication plan, in conjunction with tools and resources for staff who are re-entering a work site, is critical for ensuring that employees feel safe and are equipped to handle new processes and guidelines put into place.

Beyond the above measures, many companies have deployed one or all of the following COVID-19 specific screening practices allowed by the Equal Employment Opportunity Commission (EEOC):

  • Daily symptom questionnaires
  • Temperature checks
  • COVID-19 (C-19) testing

COVID-19 Testing Approved by FDA
Within the U.S., tests currently approved by the Federal Food and Drug Administration’s (FDA) Emergency Use Authorization (EUA) for COVID-19 are as follows:

  • Antibody Tests (also known as serology testing) – Shows if a person has been infected by coronavirus in the past
  • Diagnostic Tests (Molecular or Antigen) – Shows if a person has an active COVID-19 infection

Antibody testing is typically conducted after recovery from COVID-19. A blood sample is drawn (either by finger prick or vein in the arm) and tested to determine whether the donor has developed antibodies against the virus. At present, the Center for Disease Control (CDC) does not know if the presence of antibodies means a person is immune to the COVID-19 virus. For this reason, the CDC does not recommend the use of antibody testing to be used to detect the presence of a COVID-19 infection and antibody tests should not be used to make decisions about returning a person to the workplace.

Based upon the CDC’s stance on antibody testing pursuant to EEOC guidance from June 17, 2020, an antibody test does not meet the Americans with Disabilities Act’s (ADA) “job related and consistent with business necessity” standard for medical examinations or inquiries for employees/candidates; therefore, requiring antibody testing before allowing employees to re-enter the workplace is not allowed under the ADA (as enforced by the EEOC).

Diagnostic tests (molecular or antigen) may be used to determine if someone has an active case of COVID-19 and the EEOC has ruled that these types of tests are permissible under the ADA.

When Can Employers Test?
Under the EEOC, employers can only require their employees to take a COVID-19 test (diagnostic) that looks for actual infection. In my mind, there are two employer use cases for this type of testing:

  • Ad Hoc Testing– As the name implies, this is “as-needed” testing for employees suspected of having the COVID-19 virus either based upon displayed symptoms or exposure. An employer (based on their policy) can compel a COVID-19 diagnostic test for one or more of their employees. As a best practice, the employer should remove the employee from the jobsite until the test is completed. If the person tests positive, they should quarantine and remain out of work until symptom free for at least 10 days. The person is eligible to return to work after this waiting period is completed. Based on the most recent CDC information, repeat testing for return to work is at the employer’s discretion.
  • Assurance Testing – Assurance testing is a form of surveillance testing, but instead of tracking at-risk groups, it tracks an entire workplace to make sure new cases are not happening. It’s important to remember that before symptoms begin, people who are infected are “pre-symptomatic” and can infect others. There are also people who are asymptomatic (infected and experiencing or displaying no symptoms). This type of testing would help find those individuals that would not be detected when prioritizing testing to only those who are symptomatic. Many of the universities that have returned students to campuses have deployed assurance testing and conduct testing on students at least weekly (some schools test several times per week). As noted above, this type of testing should be done at minimum on a weekly basis, and it requires laboratory networks with enough throughput to post results within one day. As with ad hoc testing, individuals who test positive should be removed from work until asymptomatic for at least 10 days.

Learn more about HireRight’s COVID-19 Screening Solution, available for both ad hoc and assurance testing of your workforce.

Testing Considerations
Employers should consider creating a policy that addresses the following: when an employee must take a test, the specific test or tests that will be conducted, and the consequences of an employee’s refusal to be tested. In addition, employers must make sure that all COVID-19 screening policies adhere to relevant state and local guidelines, which can differ significantly by jurisdiction.

When choosing a diagnostic test, employers should review its reported accuracy and only use tests approved by the FDA with Emergency Use Authorization (EUA). In part 2 of this blog, I will be covering the various tests available in the market, the pros and cons associated with each type of test and provide some best practice recommendations to get you started on a testing program.

For additional information on HireRight’s self-administered COVID-19 screening solutions, including ad hoc and assurance testing, visit https://www.hireright.com/services/drug-health-screening/COVID-19-Screening.


Dr. Todd Simo

Dr. Simo is the Chief Medical Officer and the Managing Director of Transportation at HireRight. He served as HireRight’s Medical Director starting in 2009 and was promoted to Chief Medical Officer in 2015. Dr. Simo was also appointed to the role of Managing Director of Transportation in 2018. Dr. Simo came to HireRight with a decade of experience in the medical consulting arena. Before that he was Medical Director at an occupational health clinic in Virginia and owned a consulting firm providing medical director services to employers across the United States.

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