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

Melanie Swift, MD, MPH

(she/her)
Practice Chair, Division of Preventive, Occupational, and Aerospace Medicine

Medical Director, Mayo Clinic Physician Health Center

Associate Medical Director, Occupational Health Service

Co-Chair, COVID Vaccine Allocation and Delivery

_______________________________
Mayo Clinic
200 First Street SW
Rochester, MN 55905

From: MCOH-EH <mcoh-eh-bounces@mylist.net> On Behalf Of Abhijay Karandikar via MCOH-EH
Sent: Friday, September 17, 2021 4:30 PM
To: mcoh-eh@mylist.net
Cc: Abhijay Karandikar <dr_abhik@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?

Thanks!

Abhijay

Abhijay P. Karandikar, MD, MPH, FACOEM

Section Chief, Occupational Medicine & Employee Health 
Medical Director, Occupational Claims   
West Reading, PA 19611