Note: This piece has been updated with recent changes in the EEOC testing guidelines.
As many organizations face a case surge due to BA.5, managers need to ensure that only health employees are entering the office to avoid disruptive outbreaks. Companies will need to ensure their safety policy is compliant with the updated EEOC guidelines. A daily screening solution can help protect your community from the silent spread of infection, however, employers will also need a strong testing solution to effectively combat outbreaks.
This blog reviews overall best practices for testing in the workplace and evaluates each testing option to help employers beat case surges.
Can You Mandate Employee COVID-19 Testing?
It depends, the U.S. Equal Opportunity Commision (EEOC) and Americans with Disabilities Act of 1990 (ADA) requires that mandatory medical tests of employees are “job related and consistent with business necessity”. Previously, "business necessity" was assumed to be threat of COVID but now employers need to have a business reason. According to the EEOC in order to meet the “business necessity” standard, employers need to:
- Level of community transmission
- Vaccination status of employees
- Accuracy and speed of different types of tests
- The breakthrough rate for vaccinated employees
- The transmission rate for the current variant
- The possibility of severe illness
- Impact on operations
- If staff comes into contact with folks deemed medically vulnerable
If, after this, a company determines that there is no reason to implement screening testing for COVID then they should stop testing. However, amidst the BA.5 variant this may not be the case for many organizations.
Quickly evaluate "business necessity" with digital tools
In order for business to prove "business necessity" they have two options: conduct extensive research into the health status of their employees daily through siloed spreadsheets OR adopt digital tools to get the data in real time to prove why they need a testing solution in place.
According to our customers digital tools have saved them hours and tons of manpower. Save time and utilize our system to prove when there is a justified need for testing and create a healthy environment for employees.
See how ReturnSafe's digital tools meet the EEOC criteria for required testing.
|Level of community transmission||
Use our COVID Risk Predictor to see the levels of community
|Vaccination status of employees||
With our vaccine tracking dashboard employers can easily
|Accuracy and speed of different types of tests||
Read the rest of our blog to assess the accuracy and speed of
|The breakthrough rate for vaccinated employees||
The breakthrough rate can easily be calculated utilizing our custom reports
|The possibility of severe illness||
Employers can utilize our case management tools to determine
|The transmission rate for the current variant||
Employers can see how the current variant is impacting case surges
|Impact on operations||
Employers can see the number of cases in our dashboard and easily
|If staff comes into contact with folks deemed medically vulnerable||This is determined by the type of organization you are in. If there is
any confusion, our team of experts can help you identify if you meet this
Now that you've decided to implement or updating your testing policy with digital tools, what test option will you choose? The EEOC asks employers to assess the accuracy and speed of different options. We've put together some information to help as you decide on the right testing solution for your organizations.
PCR versus Antigen
You should evaluate which type of COVID-19 test would work best for your organization. Currently there are two types of diagnostic tests for COVID-19, PCR and Antigen. PCR tests are the gold standard in terms of accuracy. However, these tests are generally more expensive and take longer to deliver results than Antigen.
Antigen tests are more accurate if the operator is someone already experienced with the testing system. Organizations can use the BD Veritor System to improve accuracy. Due to demand for this system by the federal government this system is not always accessible.
Another option is to use both Antigen and PCR Tests. You can use Antigen as your primary test and PCR as the secondary test if you suspect a false positive. In this case, you can use PCR to verify the result, so you don’t lose employee productivity.
You should evaluate which diagnostic test works best for your organization. Once you have decided, the next step is to decide on the best testing method.
|Type of test||What it detects||Level of Accuracy||Time to Results||Estimated Cost/Test|
|Antigen||Detects specific proteins from the active virus||Medium||15 minutes||$5 – $35|
|PCR||Detects active virus genetic material||High||48 Hours||$65 – $150|
At Home Testing
Employees can order and self-administer at home tests. This can be a benefit for companies that wish not to be directly involved in employee COVID-19 testing. The turnaround time for at home tests ranges from a few minutes to a few days. Employees and human resource administrators should ensure these testing providers have obtained an FDA Emergency Use Authorization (EUA).
A drawback of at-home tests is that administrators cannot verify the designated employee self-administered a COVID-19 test accurately.
The test’s accuracy is also dependent on the employee’s administration. Administrators concerned about accuracy and compliance should choose tests that are relatively easy to use.
Experienced professionals administer on-site tests to employees at a work site. As opposed to at-home tests, human resources can verify that the operators administered COVID-19 tests to the right employee. On-site testing encourages compliance since employees can access the resource at work.
Companies that test on-site create a positive and trusting work environment. Employees feel supported when businesses are proactive about health and safety.
On-site testing is a great option for essential businesses and other high-risk organizations. In these industries, administrators must confirm employees received the right test and react immediately to positive test results. On-site testing is also the best option for businesses with a large number of employees.
A disadvantage of on-site testing is that businesses are taking on the responsibility of testing. When on-site testing, you must ensure that your labs are following the appropriate sanitation and privacy protocol. Additionally, you must adhere to federal guidelines regarding on-site testing.
If your company wishes to do on-site testing, you must adhere to federal mandates for employee COVID-19 testing. Businesses must obtain a CLIA license or hire an organization with a mobile CLIA lab certificate to do on-site testing.
External testing providers, outside of an organization’s worksite, provide off-site testing for employees. Similar to on-site tests, professionals can confirm that the right employees received the COVID-19 test. Off-site testing centers often have better equipment than those on-site, which can improve the accuracy of test results. Best of breed off-site testing centers assess employee COVID-19 tests as soon as possible.
There are some issues that can arise with off-site testing. For example, an employee COVID-19 testing location separate from your worksite may be inaccessible. If employees have to travel outside of work for a test this might diminish compliance. Additionally, off-site testing is less effective if there is a slow turnaround time.
When evaluating a solution, you should consider which testing options are best fit for your organization in the long-term.
No matter which option you choose, employers need a solution for managing the entire testing process. You should encourage all employees reporting symptoms or exposure to seek testing. In addition, you should consider establishing a broad-based testing program for everyone’s safety. This program should allow you to see positive test results immediately.
An effective test management system should also integrate with a case management solution. This solution should provide a list of the close contacts of employees infected with COVID-19 and their contact information. Once you have this information, your team should send the appropriate advisories to these employees as soon as possible to prevent further infection.
Beyond a strong diagnostic testing system, employers should use testing as a risk mitigation tool. Companies can regularly test all or a sample of employees to identify high-risk areas of infection at the workplace. This process is known as surveillance testing. Surveillance testing also allows employers to capture potentially asymptomatic employees.
As an HR leader, you should have one centralized and secure location where you can store important testing information and manage risk. The solution should be scalable, customizable, and integrate with other health safety tools. Our platform provides health screening, testing, and case management tools to help employers prevent outbreaks.
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