Issue Briefs

Image: Cryptographer/

Following are key sections of new CDC guidance on testing of federal employees including options for agencies in certain scenarios.

Considerations for Testing for SARS-CoV-2 Infection


Federal agencies can incorporate SARS-CoV-2 testing as part of a comprehensive approach to reducing transmission in non-healthcare workplaces. CDC recommends a layered approach to reduce workplace exposures to SARS-CoV-2. Symptom screening, testing, and contact tracing are strategies to identify workers infected with SARS-CoV-2 so that actions can be taken to slow and stop the spread of the virus. Disclosures and Consent Elements Employees undergoing testing should receive clear information on

• The manufacturer and name of the test, the type of test, the purpose of the test, the performance specifications of the test, any limitations associated with the test, who will pay for the test, how the test will be performed, how and when they will receive test results, and;

• How to understand what the results mean, actions associated with negative or positive results, the potential need for confirmatory testing, the difference between testing for workplace screening versus for medical diagnosis, who will receive the results, how the results may be used, and any consequences for declining to be tested. Individuals tested are required to receive patient fact sheets as part of the test’s emergency use authorization (EUA). Pursuant to the Americans with Disabilities Act (ADA), when employers implement any mandatory testing of employees, it must be “job related and consistent with business necessity.”

• In the context of the COVID-19 pandemic, the EEOC notes that testing to determine if an employee has a SARS-CoV-2 infection with an “accurate and reliable test” is permissible as a condition to enter the workplace because an employee with the virus will “pose a direct threat to the health of others.”

• EEOC notes that testing administered by employers that is consistent with current CDC guidance will meet the ADA’s business necessity standard.

• Workplace-based testing should not be conducted without the employee’s consent.

• Employers who mandate workplace testing for SARS-CoV-2 infection should discuss further with employees who do not consent to testing and consider providing alternatives as feasible and appropriate, such as reassignment to tasks that can be performed via telework. Testing Locations and Test Site Reporting Requirements


• Federal agencies should identify how to refer or provide diagnostic testing for employees who develop symptoms or have a known or suspected exposure to SARS-CoV-2. Some examples include an occupational medicine provider, nearby testing facilities, local healthcare institutions, or in consultation with the local or state health department.

• Alternatively, federal agencies can establish onsite capacity for diagnostic or screening testing. Point-of-care testing sites need to obtain a Clinical Laboratory Improvement Amendments (CLIA) certificate of waiver. Some work-based healthcare professionals (e.g., occupational health nurses) may perform SARSCoV-2 testing in work-based health centers if they are trained in specimen collection and performing the test according to the manufacturer’s instructions. It is important that work-based healthcare professionals also have access to, and training on, the proper use of personal protective equipment (PPE).

• Every SARS-CoV-2 testing site (sometimes called COVID-19 testing site) is required to report diagnostic and screening test results to the appropriate state or local health officials . Recordkeeping The Occupational Safety and Health Administration (OSHA) has issued Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace and interim guidance for enforcing the requirements of 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illness, with respect to the recording of occupational illnesses, specifically cases of COVID-19.

• Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19 on Form 300 logs if the following requirements are met: (1) the case is a confirmed case of COVID-19; (2) the case is work-related (as defined by 29 CFR 1904.5); and (3) the case involves one or more relevant recording criteria (set forth in 29 CFR 1904.7) (e.g., medical treatment beyond first aid, days away from work).

• Employers must follow the requirements in 29 CFR 1904 when reporting COVID-19 fatalities and hospitalizations to OSHA. More information is available on OSHA’s website. Employers should also report outbreaks to health departments as required and support their contact tracing efforts.

• Employers are encouraged to frequently check OSHA Injury and Illness Recordkeeping and Reporting Requirements webpage for updates.

SARS-CoV-2 Testing Scenarios


Diagnostic Testing

Testing persons with signs or symptoms consistent with COVID-19 Federal agencies should refer any employee with signs and symptoms of COVID-19 for diagnostic testing.

• CDC recommends that any unvaccinated person with symptoms of COVID-19 be tested and follow the advice of the person’s healthcare provider. Fully vaccinated federal employees with symptoms of COVID-19 should consult their healthcare provider or a public health professional about the need for testing.

• Federal agencies should identify where to refer employees for diagnostic testing.

• Federal agencies should advise employees to stay home if they are sick.

• Federal agencies should conduct daily in-person or virtual health checks (e.g., symptom and temperature screening) to identify employees with signs or symptoms consistent with COVID-19 before they enter a facility, in accordance with CDC’s Guidance for Businesses and Employers Responding to Coronavirus Disease 2019.

• Workers with COVID-19 symptoms should be immediately separated from other employees, customers, and visitors, and sent home or to a healthcare facility, depending on how severe their symptoms are, and follow CDC guidance for caring for oneself.

• Symptomatic workers waiting for test results should isolate at home to keep potentially infected workers out of the federal workplace.

• Federal employees are encouraged to implement flexible, nonpunitive sick leave and supportive policies as part of a comprehensive approach to prevent and reduce transmission among employees.

• Positive test results using a viral test should be interpreted to indicate that a person has COVID-19 and should not come to work and should isolate at home. Decisions to discontinue isolation for workers with COVID-19 and allow them to return to the workplace may follow either a symptom-based, time-based, or a test-based strategy. In most cases, a test-based strategy to end isolation is not recommended (see the “How to determine resolution of infection” section below). Testing asymptomatic persons with recent known or suspected exposure to SARS-CoV-2 Federal employees who have been exposed at work or outside of work should receive diagnostic testing.


• Because of the potential for asymptomatic and pre-symptomatic transmission of SARS-CoV-2, it is important that workers exposed to people with known or suspected COVID-19 be quickly identified and quarantined. While CDC continues to recommend a 14-day quarantine for unvaccinated individuals who are close contacts of a person with COVID-19, viral testing may also be used as part of an option to shorten the quarantine period.

• Viral testing is recommended for workers immediately after being identified as a close contact, and if negative, they should be tested again in 5–7 days after last exposure or immediately if symptoms develop during quarantine.

• For workers who previously received positive test results and do not have symptoms of COVID-19, retesting is not recommended for up to 3 months from their last positive test result, and they do not have to quarantine as long as they do not develop new symptoms.

• Most workers who are fully vaccinated against COVID-19 are not required to quarantine or be tested if they are exposed, if they show no symptoms; however, they should still monitor for symptoms of COVID-19 for 14 days following an exposure. Fully vaccinated workers in non-healthcare congregate settings and other high-density workplaces should be tested after an exposure. Federal agencies should provide diagnostic testing for employees who had close contact (within 6 feet for a combined total of 15 minutes or more during a 24-hour period) with persons with COVID-19 at work.


• This testing should be provided at a convenient place and time and at no cost to the employee. Federal agencies should refer or provide diagnostic testing for any employee who had close contact (within 6 feet for a combined total of 15 minutes or more during a 24-hour period) with persons with COVID-19 outside of work. Federal agencies can consider providing diagnostic testing for employees who might have been in close contact (possible contacts) in the workplace with persons diagnosed with COVID-19.

• A risk-based approach to testing possible contacts of a worker with confirmed COVID-19 may be applied. Such an approach should take into consideration the likelihood of exposure, which is affected by the characteristics of the workplace and the results of contact investigation.

• Broader testing (i.e., testing beyond individually identified close contacts to those who are possible close contacts), such as targeting workers who worked in the same area and during the same shift, but not identified as close contacts, may be considered as part of a strategy to control the transmission of SARSCoV-2 in the workplace. High-risk settings with potential for rapid and widespread dissemination of SARS-CoV-2 include: o Workplaces where workers are in the workplace for long periods (e.g., for 8–12 hours per shift) and have prolonged close contact with coworkers (e.g., working in an air traffic control tower). o Workplaces where employees live in communal living arrangements (e.g., workers on vessels or in wildland firefighter camps). o Workplaces with populations at increased risk for severe illness if they are infected and workplaces in rural areas or with older workers. o Workplaces where the risk to the government’s mission is high if an outbreak occurs

• Onsite testing capacity, if developed, may be exceeded when many workers participate in broader testing. Performing Broad-Based Testing for SARS-CoV-2 provides consideration on the logistics of broader testing. Alternatively, broader testing can be performed at other testing locations. Federal agencies can consider offering testing as part of an option to shorten the quarantine period to mitigate staffing shortages, but this is not the preferred option for reducing the risk of SARS-CoV-2 transmission.

• Federal agencies should consider workplace characteristics when determining if this additional transmission risk is acceptable (e.g., level of community transmission, ability to maintain physical distancing, proportion of employees at increased risk for severe illness, and priority of operations).

Screening Testing

Testing asymptomatic persons without known or suspected exposure to SARS-CoV-2 Viral testing of asymptomatic workers without known or suspected exposure to SARS-CoV-2 (screening testing) may be useful to detect SARS-CoV-2 early and stop transmission quickly, particularly in areas with community COVID-19 indicators in the moderate to high categorizations (Table 2, Table 3). Persons with asymptomatic or presymptomatic SARS-CoV-2 infection are significant contributors to SARS-CoV-2 transmission. Screening testing should be used as an addition to, not as a replacement for, other prevention strategies. Fully vaccinated workers should continue to follow employer guidance, such as Executive Order on Protecting the Federal Workforce and Requiring Mask-Wearing and OMB Memorandum M-21-15, COVID-19 Safe Federal Workplace: Agency Model Safety Principles. Please see Interim Public Health Recommendations for Fully Vaccinated People for more information. Types of federal workplaces that might consider implementing screening include:

• Workplaces at increased risk of introduction of SARS-CoV-2 (e.g., workplaces where workers are in close contact with the public or workplaces in communities with moderate to high transmission).


• Workplaces where there is a higher risk of SARS-CoV-2 exposure or transmission (e.g., workplaces where physical distancing is difficult and workers might be in close contact).

• Workplaces where SARS-CoV-2 infection among employees will lead to greater negative impact, such as o Workplaces in remote settings where medical evaluation or treatment may be delayed. o Workplaces where continuity of operations is a high priority.

Guidance for federal agencies implementing a screening testing program

Type of test

• Important attributes to consider when selecting the type of test or tests used for screening include ready availability, cost, and rapid turnaround time.

• A screening program with either NAATs or antigen tests could be effective in helping to prevent transmission.

• Table 1 summarizes some characteristics of NAATs and antigen tests to consider for a screening testing program.

• Employees with a positive NAAT result should not come to work and should isolate at home. A negative NAAT result is interpreted as no evidence of SARS-CoV-2 infection at the time when the testing specimen was collected. Employees who test negative should continue to take steps to protect themselves and others.

• Some antigen test results should be considered presumptive (preliminary results) and require confirmatory testing. Asymptomatic employees who have a positive antigen screening test result should undergo a laboratory-based confirmatory NAAT. They should not come to work and should quarantine at home during confirmatory testing. Refer to CDC’s Interim Guidance for Antigen Testing for SARS-CoV2 for more information on how to interpret antigen test results.

Frequency of screening testing


Serial testing is testing that is repeated over time (e.g., weekly), either on the same individual or on the same group (e.g., a workplace or segment of a workplace).

• Serial testing is primarily used for screening but could also be used for diagnostic purposes.

• Because there could be a delay between the time a person is exposed to the virus and the time the infection can be detected by testing, early testing after exposure at a single time point might miss many infections.

• Serial testing can be more likely to detect infection than testing done at a single point in time. It can also help identify persons who were originally not exposed nor infected but who subsequently became exposed and infected during the time between tests. Federal workplaces should consider the following factors when determining the frequency of screening testing:

• Availability of testing, short turnaround time (e.g., same day), and cost.

• Latency time period between exposure and development of a positive SARS-CoV-2 viral test.

• Workplace characteristics.

• Level of community transmission (Table 2, Table 3).

• How many employees tested positive during previous rounds of testing.

• Relevant experience with outbreaks at the workplace.


CDC Sets Policies on Federal Employee Virus Testing; Some Agency Discretion

Guidance Outlines Obligations to Employees in Virus Testing

Pandemic Causes Personnel Increase, Shift in Federal Work

OPM Reports on Telework’s Past, Hints at Its Future

OPM Sets Policies on Verifying FEHB Eligibility for Family Members

2022 Federal Employees Handbook