[MCOH-EH] [EXTERNAL] Testing for COVID vaccine exempt employees

Cloeren, Marianne MCloeren at som.umaryland.edu
Thu Oct 28 11:24:03 PDT 2021

Thank you, Sally!

Candidate forum next week, Friday November 5, 1:30 to 3:15 central time - nice way to get to know all the candidates and make an informed choice. Register for it here: https://acoem.org/About-ACOEM/Governance/Meet-the-Candidates


Marianne Cloeren, MD, MPH, FACOEM, FACP
Pronouns: She/Her/Hers
Associate Professor
University of Maryland School of Medicine
Division of Occupational and Environmental Medicine
mcloeren at som.umaryland.edu<mailto:mcloeren at som.umaryland.edu>
Office 410-328-2637
Cell 443-466-0033
No response needed/expected after 5 PM or on weekends.

From: MCOH-EH <mcoh-eh-bounces at mylist.net> On Behalf Of Sally Foster-Chang
Sent: Wednesday, October 27, 2021 1:55 PM
To: MCOH-EH <mcoh-eh at mylist.net>
Subject: Re: [MCOH-EH] [EXTERNAL] Testing for COVID vaccine exempt employees

Marianne Cloeren has just declared her candidacy for ACOEM VP. I was asked to spread the word. She has a plethora of experience in all areas of OH and is Incredibly hard working. Go Marianne!

On Wed, Sep 29, 2021 at 1:56 PM Swift, Melanie D., M.D., M.P.H. via MCOH-EH <mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>> wrote:
We are awaiting the CMS regulations to determine testing requirements and frequency, which may drive some of the logistic decisions.

Current CMS regulations for LTC facilities require routine testing of unvaccinated staff at intervals determined by local disease levels, require that facilities offer or facilitate vaccination, provide education regarding vaccination, and submit a weekly report of vaccination rates and other metrics, but do not require that employees take vaccination.

In August CMS announced they would be revising this to reflect mandating vaccination, and there is speculation that whatever that requirement is would be expanded to all healthcare facilities that receive CMS funding, but we do not yet know whether routine testing will be required for unvaccinated staff. Probably it will be, but the changing frequency based on local disease levels can be quite challenging for multisite healthcare systems to manage, so hopefully it will be something simpler. Based on disease activity, the current LTC testing can be as frequent as twice a week.

Even if not required by CMS regs, the anticipated OSHA ETS for employers with over 100 employees would likely apply, and we do know that would require weekly testing of unvaccinated staff. So unless healthcare is carved out of that ETS we expect at least weekly testing.

CMS is reportedly going to publish an interim rule within the next 1 - 2 weeks, so we should know more soon.


Melanie Swift, MD, MPH
Practice Chair, Division of Preventive, Occupational, and Aerospace Medicine
Medical Director, Mayo Clinic Physician Health Center<https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.mayoclinic.org%2Fdepartments-centers%2Fpreventive-occupational-aerospace-medicine%2Fphysician-health-center%2Freferrals&data=04%7C01%7Cmcloeren%40som.umaryland.edu%7C694e3db5c81c45795aa508d99a3df063%7C717009a620de461a88940312a395cac9%7C0%7C0%7C637710414300378434%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=INc7rtO0QhJcvPvvzkY%2F1Q68w1vHHRWdTZsjU0Q49Hw%3D&reserved=0>
Associate Medical Director, Occupational Health Service
Co-Chair, COVID Vaccine Allocation and Delivery
Mayo Clinic
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From: MCOH-EH <mcoh-eh-bounces at mylist.net<mailto:mcoh-eh-bounces at mylist.net>> On Behalf Of Abhijay Karandikar via MCOH-EH
Sent: Friday, September 17, 2021 4:30 PM
To: mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>
Cc: Abhijay Karandikar <dr_abhik at yahoo.com<mailto:dr_abhik at yahoo.com>>
Subject: [EXTERNAL] [MCOH-EH] Testing for COVID vaccine exempt employees

Hi all,

Could you please take some time to answer these questions regarding unvaccinated employees who you grant exemptions from receipt of the COVID-19 vaccine(s), either medical or religious:

1. Which PCR test platform are you using: Panther, LIAT, ID Now, etc.?

2. At what frequency will you test exempt employees: Once a week, twice weekly, other?

3. Who is performing the test: the employees themselves, Employee Health, Urgent Care, other?

4. If the weekly tests are performed outside EH, how would employees send the swabs to the lab?

5. Lastly, do you require remote exempt employees to test at the same frequency or only if they are anticipated on campus? If they are self testing at home, how do you deal with "chain of custody" issues?


Abhijay P. Karandikar, MD, MPH, FACOEM
Section Chief, Occupational Medicine & Employee Health
Medical Director, Occupational Claims
West Reading, PA 19611

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