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Testing

Q: What is screening testing?

A: Screening tests are intended to identify infection with SARS-CoV-2, the virus that causes COVID-19, in unvaccinated people who are asymptomatic and do not have known, suspected, or reported exposure to SARS-CoV-2. Screening helps to identify unknown cases so that measures can be taken to prevent further transmission. Screening testing is separate and distinct from diagnostic testing, which should be performed on anyone that has signs and symptoms consistent with COVID-19 or following recent known or suspected exposure to SARS-CoV-2.

UpdatedQ: Should agencies establish a screening testing program for SARS-CoV-2, the virus that causes COVID-19?

A: Yes, agencies should establish a COVID-19 screening testing program by February 15, 2022 for employees who are not fully vaccinated.

An agency generally does not need to include onsite contractor employees or fully vaccinated employees in its screening testing program. For certain roles, functions, or work environments, an agency may determine that it is necessary that certain onsite contractor employees, certain employees regardless of their vaccination status, or certain employees and certain onsite contractor employees regardless of their vaccination status must participate in screening testing, given operational or administrative considerations associated with conducting screening testing for those roles, functions, or work environments.

UpdatedQ: What testing protocols should be applied through an agency’s screening testing program to employees who are not fully vaccinated?

A: When COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), employees who are not fully vaccinated and who work onsite should undergo regular screening testing through their agency’s screening testing program. This includes employees who do not work at a Federal facility but who interact in person with members of the public as part of their job duties, such as safety inspectors.

For purposes of regularly testing these employees through a screening testing program, an employee enrolled in the program should be tested weekly for any week during which they work onsite or interact in person with members of the public as part of their job duties. Agencies may require more frequent testing, such as for certain roles, functions, or work environments. Testing may be conducted at a Federal facility or offsite as determined by the agency. The test should not be both self-administered and self-read by the employee unless observed by the agency or an authorized telehealth provider.

UpdatedQ: Do Federal employees or contractor employees participating in an agency screening testing program need to be able to provide the results of a negative test in order to enter or be present in a Federal facility?

Federal employees participating in an agency screening testing program do not need to be able to provide the results of a negative test each time they enter or are present in their agency’s facilities, unless required as part of the agency’s screening testing program and workplace safety protocols. That said, Federal employees generally are treated as visitors during a visit to another agency, so while they are onsite at another agency’s worksite when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), they should be able to show proof of a negative COVID-19 test result administered within the past 3 days, if they are not fully vaccinated or decline to provide their vaccination information to the host agency.

Similarly, contractor employees participating in an agency testing program do not need to be able to provide the results of a negative test each time they enter or are present at that agency’s facilities when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), unless required as part of the agency’s testing program and workplace safety protocols. However, if they are visiting another agency’s facilities, they should be able to show proof of a negative COVID-19 test result administered within the past 3 days, if they are not fully vaccinated or decline to provide their vaccination information to the host agency.

UpdatedQ: Do the screening testing protocols apply to employees who are not fully vaccinated and who are not reporting to their worksite (e.g., are on maximum telework, working remotely, or on leave)?

A: No, employees who are working remotely or who are on maximum telework do not need to undergo regular testing. An employee who does not report to a worksite or interact in person with members of the public as part of their job duties during a particular week (e.g., due to taking leave, teleworking, or working remotely) does not need to be tested that week.

Should these employees have a one-time need to report to one of their agency’s facilities, they should be tested in the week they are entering the facility when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions). Should these employees need to be onsite at another agency’s facility when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), they generally would be treated as visitors during their visit, and so should be able to show proof of a negative COVID-19 test result administered within the past 3 days.

UpdatedQ: Do the screening testing protocols apply to Federal employees who are not fully vaccinated and who only work onsite on an infrequent basis?

A: Federal employees who are not fully vaccinated and who work onsite or interact in person with members of the public as part of their job duties on an infrequent basis should be tested at least once in the week that they are working onsite or interact in person with members of the public as part of their job duties. An agency may determine that some employees who generally do not report to a worksite or interact with members of the public as part of their job duties, but may need to do so on an emergency basis (e.g., for accident investigations or disaster response) are required to undergo regular testing when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), on a frequency determined by the agency.

Should these Federal employees need to be onsite at another agency’s facility when COVID-19 Community Levels are MEDIUM or HIGH (see FAQs on Local Conditions), they generally would be treated as visitors during their visit, and so would need to be able to show proof of a negative COVID-19 test result administered within the past 3 days.

Q: What types of tests may an agency utilize for a screening testing program?

A: For screening testing programs, agencies may utilize any viral tests authorized by the Food and Drug Administration (FDA) to detect current infection. There are two types of viral tests: antigen tests and nucleic acid application tests (NAATs). Reverse transcriptase polymerase chain reaction (RT-PCR) tests are a type of NAAT. Agencies should consult FDA guidance for specific authorized tests impacted by COVID-19 variants and the current status on recommended use.

Options for testing methods include: (1) in-store or drive-through point-of-care (POC) testing, such as at pharmacies, (2) swab-testing capabilities that enable an individual to collect the specimen—using a self-collection kit—and drop it off at a designated collection location or ship it to a laboratory, (3) over-the-counter (OTC) tests, as long as those tests are not both self-administered and self-read by the employee unless observed by the agency or an authorized telehealth provider, or (4) other self-administered tests, as long as those tests are not also self-read by the employee unless observed by the agency or an authorized telehealth provider.

Agencies should establish a means of verifying the date and result of a test—the test should not be both self-administered and self-read by the employee unless observed by the agency or an authorized onsite or telehealth provider. If the results are provided to the Federal employee or contractor employee who was tested, the agency should establish a means for the Federal employee or contractor employee to provide those results to the appropriate agency staff for verification that required testing has been completed and the employee has tested negative. Agencies must comply with applicable privacy safeguards and regulations when receiving test results.

UpdatedQ: What steps may an agency take if a Federal employee refuses to take a COVID-19 test required pursuant to that program?

A: Refusals to take a required test or to provide the results of the test may result in disciplinary measures. In addition to pursuing any disciplinary action, an agency may separately elect to bar the employee from the agency workplace for the safety of others pending resolution of any disciplinary or other action the agency may pursue. Any decision to bar the employee should occur in consultation with the agency’s onsite security authority, agency’s human resources office, and agency’s legal counsel. In pursuing an adverse action, the agency must also follow normal processes to provide the required notice to the employee.

An agency follows a different process if the employee seeks an accommodation from the requirement to be regularly tested. In that case, an agency should follow its ordinary process to review and consider what, if any, accommodation should be offered in accordance with Federal employment nondiscrimination laws. All agency personnel designated to receive requests for disability accommodations should also know how to handle requests consistent with other Federal employment nondiscrimination laws that may apply. While the request is being resolved, the agency may bar the employee from official worksites. During that temporary period, the agency may direct the employee to work from home. If the employee’s duties cannot be performed via telework, the employee should be granted administrative leave for the temporary period of time while the request is being resolved.

If the employee’s request for an accommodation to a testing requirement is denied, and the employee does not comply with the testing requirement, the agency may pursue disciplinary action up to and including removal.

Q: Are agencies required to pay for the cost of testing employees pursuant to a screening testing program?

A: Yes, agencies are required to pay for the cost of screening testing of Federal employees pursuant to the agency’s screening testing program. Agencies are also responsible for paying the cost of required testing should an employee visit another Federal agency if the employee’s agency has approved the visit in advance. Agencies can either pay for the testing directly or reimburse employees for required tests. Should agencies have questions regarding their approach to funding this testing from agency appropriations, they should contact their respective OMB Resource Management Office.

Q: Can agencies utilize pooled specimen testing in a screening testing program?

A: Yes, agencies can utilize pooled specimen testing, assuming the screening testing program utilizes any COVID-19 viral test that is used to detect current infection and has been authorized by the Food and Drug Administration for use in pooled testing. Agencies should consult FDA guidance for specific authorized tests impacted by COVID-19 variants and the current status on recommended use.

Pooled specimen testing combines the same type of specimen from several people and conducts one NAAT laboratory test on the combined specimen. If the pooled specimen test returns a positive result, each specimen in the pool must be retested individually. Of note, as the incidence of COVID-19 increases among the population being tested, the cost savings of a pooling strategy decreases because more pooled tests will return positive results, and those specimens will need to be retested individually to determine which individual(s) are positive.

Q: Is required screening testing undertaken on duty time?

A: Yes. When a Federal employee is required to be tested pursuant to an agency’s screening testing program, the time the employee spends obtaining the test (including travel time) from a site preapproved by the agency is duty time; thus, there is no need for the employee to take administrative leave for such time during the employee’s basic tour of duty. An agency should only authorize an employee to spend time related to screening testing during the employee’s basic tour of duty hours and only for the amount of time necessary. Agencies should determine the amount of time to authorize employees to take to travel to the testing site (if travel is required), complete testing, and return to work. Agencies should require employees taking longer than that amount of time to document the reasons for the additional time. If, due to unforeseen circumstances, the employee is unable to obtain the test during basic tour of duty hours, the normal overtime hours of work rules apply.

Reasonable travel costs that are incurred as a result of obtaining the test from a site preapproved by the agency should be handled the same way as local travel or temporary duty (TDY) cost reimbursement is handled based on agency policy and the Federal Travel Regulation.

When an employee is not required to be tested but decides to obtain a COVID-19 test during basic tour of duty hours at the employee’s own initiative, the employee may request sick leave or other available paid time off for that situation.

Q: Are Federal employees and contractor employees participating in an agency screening testing program limited in their ability to work onsite in between tests?

A: No, provided that they have met any applicable testing requirement and have not tested positive for COVID-19, Federal employees and contractor employees participating in an agency screening testing program are not limited in their ability to work onsite between tests, although they should comply with all relevant safety protocols. However, if the employee or contractor employee has come into close contact with a person with COVID-19 during this time, they should follow CDC guidelines for testing and quarantine, as well as any other requirements set forth in agency workplace safety protocols. Similarly, if they have symptoms consistent with COVID-19, they should follow agency protocols and not enter a worksite.

Agencies should develop a procedure for addressing circumstances in which employees or onsite contractor employees miss their required test, which may include restricting the individual’s access to worksites if they have not obtained a test within a period of time specified by the agency.

An employee’s failure to comply with testing requirements can result in disciplinary action, up to and including removal. An agency may separately elect to bar the employee from the agency workplace for the safety of others pending resolution of any disciplinary action. A contractor employee’s failure to comply with testing requirements may result in that individual being denied entry to a Federal facility. Such circumstances do not relieve the contractor from meeting all contractual requirements.

Q: What is diagnostic testing?

A: Diagnostic testing is intended to identify current infection in individuals and should be performed on anyone that has signs and symptoms consistent with COVID-19 and/or following recent known or suspected exposure to SARS-CoV-2. This includes, for example, testing of individuals who have symptoms of COVID-19, which should be done as soon as possible after symptoms development, and testing of individuals who have come into close contact with someone with COVID-19, which should be done to check for infection at least 5 days after the individual last had close contact with someone with COVID-19 (the date of the last close contact is considered day 0).

Q: Should agencies provide diagnostic testing for employees’ work-related exposures?

A: Federal employees who have been exposed to persons with COVID-19 at work should receive diagnostic testing at no cost to the employee. Agencies that have in-house capabilities can provide diagnostic testing at the worksite; if an agency does not provide testing at the worksite, it should determine a process for employee diagnostic testing.

Q: Can an employee get reimbursed for costs related to diagnostic testing if required for official travel?

A: Yes, the cost of diagnostic testing for current infection with SARS-CoV-2, required for official travel and not available through a Federal dispensary or not covered (or reimbursable) through travel insurance, can be claimed in a travel voucher as a Miscellaneous Expense under agency travel policies.

Q: Does the employee have a responsibility to pay for diagnostic testing if the exposure is not work-related?

A: An agency is not responsible for providing diagnostic testing to an individual as a result of a potential exposure that is not work-related. An employee or contractor employee who comes into close contact with a person with COVID-19 outside of work should follow CDC guidelines for testing and quarantine consistent with their vaccination status.

Q: Can information on employee test results be stored by an agency? How must information on test results be stored? How long must the information be stored and who may have access to it?

A: Agencies have unique operational environments and may develop their own processes to document COVID-19 test results in compliance with all applicable laws and in accordance with their agency’s records management policies.

The Privacy Act statement for the testing requirements will refer to the Government-wide system of records (OPM/GOVT-10) for employee medical files (EMFs), which is governed by OPM regulations (5 C.F.R. part 293, subpart E). Under those rules, each agency must have written instructions for its EMF system with appropriate safeguards, and must retain short-term medical records under the applicable record schedule. Agencies with positions that are not subject to OPM’s regulations or that are not subject to OPM/GOVT-10 must give their employees an alternative Privacy Act statement. The Rehabilitation Act requires that any COVID-19 related certification or vaccination information must be maintained separately from the employee’s Official Personnel Folder. The Rehabilitation Act also requires that test results be kept confidential and limits who may have access to such information. Agencies are encouraged to take steps to promote privacy and IT security, while also providing the relevant information to agency officials who need to know the test results.

Agencies should consult, as appropriate, their Agency Records Officer, Chief Information Officer, Chief Medical Officer, Senior Agency Official for Privacy, and agency legal counsel to determine appropriate information management protocols.

Q: If an employee tests positive for SARS-CoV-2 infection, is the agency required to record the COVID-19 case on the OSHA Injury and Illness Log?

A: Under OSHA’s recordkeeping requirements, if an employee tests positive for SARS-CoV-2 infection, the case must be recorded on the OSHA Illness and Injury Log if each of the following conditions 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 should also follow state and local reporting requirements and comply with state and local contact tracing efforts.

Q: Should agencies discuss any testing plans with their employee unions?

A: Agencies should engage with employee unions at their earliest opportunity as they develop any agency-specific testing plans and otherwise satisfy any applicable collective bargaining obligations under the law at the earliest opportunity, including on a post-implementation basis where appropriate.