DOI COVID-19 TESTING GUIDANCE

5/14/21

BACKGROUND

The Secretary of Health and Human Services, through the Director of the Centers for Disease
Control and Prevention (CDC), was directed to develop a testing plan for the federal workforce
based on the latest guidance from CDC. This plan was released on April 7. Based on this plan,
the Department of the Interior (DOI) has determined the following testing guidance may be
applied in certain circumstances and select DOI workplaces.

PURPOSE
The purpose of this document is to provide testing guidance for SARS-CoV-2, the virus that
causes COVID-19, for DOI employees and contractors in certain circumstances within select
DOI workplaces. While testing is always voluntary within DOI, workplace-based testing for
SARS-CoV-2 could identify DOI employees with SARSCoV-2 infection, and thus help prevent
or reduce further transmission. This guidance includes descriptions of different types of SARS-
CoV-2 tests; scenarios where SARS-CoV-2 testing may be used; and considerations for
screening testing (testing asymptomatic workers with no known or suspected exposure to SARS-
CoV-2).
This guidance is based on community transmission metrics and addresses the populations to be
tested, testing types, frequency of testing, protocols for positive test results, and coordination
with state, territorial, tribal, and local health officials for contact tracing.
These strategies should be carried out in a manner consistent with existing laws and regulations,
including laws protecting employee privacy and confidentiality. This guidance should also be
carried out consistent with Equal Employment Opportunity Commission (EEOC) guidance
regarding permissible testing policies and procedures.
Although testing has benefits for early identification and controlling outbreaks, it should be an
integrated component of the comprehensive workplace program and not used as a substitute for
other measures, such as COVID-19 vaccination, proper ventilation, temperature and symptom
screening, physical distancing, mask wearing, hand hygiene, and cleaning and disinfection.
Fully vaccinated asymptomatic employees do not need testing (unless required in select
circumstances, e.g., mission-critical travel to an area requiring a negative test for entry). For
unvaccinated asymptomatic employees, the Department may offer voluntary testing to such
employees under certain circumstances (e.g., when exposed at the workplace or when on official
travel) to determine whether the employees present a direct threat to the health and safety of the
workplace.
Types of Tests
Viral tests [antigen tests and nucleic acid amplification tests (NAATs)] are used to detect
infection with SARS-CoV-2 by evaluating whether the virus is present in respiratory specimens
or saliva. Results help identify infected people who need to isolate from other people to
minimize transmission. There are two types of viral tests:

• NAATs, such as real-time reverse transcription-polymerase chain reaction (RT-PCR), are

high-sensitivity, high-specificity tests for diagnosing SARS-CoV-2 infection. Positive
NAATs indicate a current infection or a recent infection. Most NAATs need to be
processed in a laboratory and time to results can vary (~1–3 days), but some NAATs can
provide results in about 15–45 minutes.
• Antigen tests detect the presence of a specific viral antigen. Antigen tests generally have
similar specificity but are less sensitive than most NAATs. Most of these tests are “rapid”
and provide results in minutes and thus can be used in screening programs to quickly
identify those who are likely to be contagious. Because of the performance characteristics
of antigen tests, it is necessary to confirm some antigen test results (e.g., a negative test in
persons with symptoms or a positive test in persons without symptoms) with a
laboratory-based NAAT.
Antibody (or serology) tests are used to detect previous infection with SARS-CoV-2. CDC does
not recommend using antibody testing to diagnose current infection.

Intended Uses of SARS-CoV-2 Testing in DOI Workplaces

1. Diagnostic testing (using NAATs) is intended to identify current infection and is
performed when a person has symptoms consistent with COVID-19, or when a person is
asymptomatic but has recent known exposure to SARS-CoV-2.
DOI has determined that diagnostic testing may be offered in the following settings:

• Close Contact Exposure at the workplace: If an employee is exposed at close contact (less
than 6 ft for 15 minutes) at the workplace to another employee with a positive COVID-19
test result, DOI may offer testing to unvaccinated employees immediately after being
identified as a close contact, and if negative, offer testing again in 5–7 days after the
employee’s last close contact exposure. Unvaccinated employees exposed at close
contact will not be allowed to be physically present in the workplace until they meet the
self-quarantine requirements outlined in CDC and local guidance. Fully vaccinated
employees exposed at close contact do not need testing (unless in non-healthcare
congregate settings and other high-density workplaces, or if they develop symptoms
consistent with COVID-19), and may remain physically present in the workplace (do not
need to quarantine).
• Official Mission-Critical Travel: DOI may offer testing to unvaccinated employees on
official mission-critical travel only (not personal travel) where testing is a condition of
entry and/or based on CDC guidance (1-3 days before travel and 3-5 days upon return
 from their destination), and will not be allowed to be physically present in the workplace
and be advised to self-quarantine for a full 7 days after travel. Asymptomatic vaccinated
employees do not need testing and may physically enter the workplace (i.e. do not need
to self-quarantine) after official travel.

DOI will not offer diagnostic testing in the following settings:

• Employee is symptomatic. Employee will be advised not to come to work, consult with
personal healthcare provider about getting tested and self-isolating and follow CDC/local
public health/personal health care provider guidance to determine when it is safe to return
to work.

• Employee is exposed at close contact outside workplace. Unvaccinated employees

should obtain a COVID-19 test with their local healthcare provider and may not
physically enter the workplace until they meet quarantine requirements as indicated in
CDC/local public health/personal healthcare provider guidance. Asymptomatic
vaccinated employees who were exposed to a positive case at close contact do not need
testing and do not need to quarantine (may be physically present in the workplace).

• Employee has been on personal travel.

• Assessing an employee’s status to return to the workplace after exposure/infection.

2. Screening testing (using antigen tests with confirmatory NAAT) is intended to identify
asymptomatic infected persons without known or suspected exposure to SARS-CoV-2.
Identifying persons who might be contagious but are unaware allows implementation of
measures to prevent further transmission. Screening using tests that provide rapid results,
such as point-of-care antigen tests, can be critical to interrupting SARS-CoV-2
transmission. This is especially important when community risk or transmission levels
are substantial or high. Fully vaccinated asymptomatic employees do not need testing
(unless required in select circumstances, e.g., mission-critical travel to an area requiring a
negative test for entry).
DOI has determined that screening testing may be offered in the following settings:

• DOI workplaces at increased risk of introduction of SARS-CoV-2 (e.g., workplaces

where DOI employees are in close contact [less than 6 ft for 15 minutes] with the public);
• DOI workplaces where there is a higher risk of SARS-CoV-2 transmission (e.g.,
workplaces where physical distancing is difficult and employees might be in close
contact; workplaces that provide congregate housing or work in settings such as fishing
vessels, offshore oil platforms, or wildland firefighter camps); and
• DOI workplaces where SARS-CoV-2 infection among employees will lead to greater
negative impact, such as:

o DOI workplaces in remote settings where medical evaluation or treatment

may be delayed.
 o DOI workplaces where continuity of operations is a high priority.

• DOI correctional facilities

SCREENING TESTING FREQUENCY

Frequency of screening testing could be informed by:

• Current community indicators for COVID-19 such as cumulative incidence in the past 7
days and test positivity rate, in addition to other known factors about the epidemiology of
transmission in a particular community; and
• Characteristics (e.g., size, proximity of people, duration of interaction) of the workplace.
If initial results indicate transmission is substantial or high, more frequent screening
might be needed regardless of other community indicators.
Currently CDC recommends that screening testing should be conducted at least weekly.
However, if an apparent outbreak occurs at the workplace with several employees testing
positive during previous rounds of testing, more frequent testing might be warranted.

______________________________________________________________________________
TESTING PLAN

A. Prior to implementing testing, supervisors of DOI workplaces establishing voluntary

testing (in conjunction with Bureau Safety Managers) must develop a plan for testing
that includes the following:
1. ASSESS AND ESTABLISH PROGRAM
• Evaluate the worksite to assess necessity/applicability of voluntary testing consistent with
this document.
• Determine which DOI employees will be offered voluntary testing consistent with this
document.
• Determine purpose of test (e.g., diagnostic vs screening)
• Determine type of test (e.g., NAAT vs antigen)
• Identify funding source for testing
o If funding is a concern, please address any need for funding in your plan.
• Establish a mechanism for DOI employees to schedule and obtain voluntary testing.
o Establish an agreement/contract for services. It is recommended that all screening
testing programs be established and administered via government contract or
agreement to ensure compliance with state and federal regulations associated with
medical testing. Testing in-house is not recommended as it requires a federally-
licensed physician to prescribe the tests and provide medical oversight to the
screening testing program, a federally-licensed medical provider authorized to
administer and interpret test results in a patient care setting that ensure proper
storage and handling of the tests, and a facility that operates under a Clinical
Laboratory Improvement Amendments (CLIA) Certificate of Waiver or
Certificate of Compliance/Certificate of Accreditation.
o Ensure COVID-19 precautions and mitigations are maintained at testing site.
o Establish leave status for employees who choose to participate in voluntary
testing.
o Establish procedures to ensure employee privacy including information about an
employee’s decisions to participate/not participate in employer provided testing,
employee’s eligibility to participate in testing based on vaccination status, and any
results and individual public health actions taken based on those results.

2. PROVIDE INFORMATION TO EMPLOYEE

Supervisors must ensure employees offered voluntary testing 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 the employee will receive
test results;
• How to understand what the results mean, actions associated with negative or positive
results, 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; and
• Ensure all DOI employees tested receive patient fact sheets as part of the test’s
emergency use authorization.

3. FOLLOW-UP ACTIONS
All testing plans must have procedures in place for:
• a mechanism for confirmatory testing of any positive rapid antigen tests by NAAT;
• rapid notification of all positive results to employee;
• notification of all positive results to health departments in accordance with local, state,
and federal requirements, with appropriate attention to maintaining the confidentiality of
employee medical information in accordance with applicable laws;
• notification of positive cases to the appropriate supervisory chain for identification of
close contacts and disinfection of the workplace according to CDC guidance, as well as
for reporting cases through bureau channels (including reporting in the DOI Safety
Management Information System for work-related COVID-19 cases), with appropriate
attention to maintaining the confidentiality of employee medical information in
accordance with applicable laws; and
• appropriate measures based on testing results, including instructions regarding self-
isolation and restrictions on workplace access in accordance with the DOI Workplace
Safety Plan.
Employees without symptoms and without known close contact exposure to COVID-19
may be physically present in the workplace while awaiting screening test results.
However, if an employee tests positive on a screening test and is referred for a
confirmatory test, they cannot physically enter the workplace and should be advised to
self-quarantine until they receive the results of their confirmatory test. All persons
(independent of vaccination status) with positive confirmatory results should be advised to
self-isolate away from the workplace.

4. PROPER PROTECTION OF PERSONAL INFORMATION AND MEDICAL

RECORDS
Even though COVID-19 testing is voluntary, it is considered a medical examination. All
screening testing plans must include a process for the appropriate handling of medical
documentation in accordance with applicable law, including provisions of the Americans
 with Disabilities Act applied to the Federal Government through the Rehabilitation Act of
1973 and the Privacy Act, and medical documentation must be maintained in the
Employee Medical Folder, stored separately from the employee's personnel file.

B. Once plan is developed, it must be signed by the Bureau or Office Director and
Assistant Secretary, and approved by the DOI COVID-19 Leadership team before
implementation. Fully signed plans should be submitted to the Interior Operations
Center (doi_watch_office@ios.doi.gov) for review by the Office of Occupational Safety
and Health and approval by the DOI COVID-19 Leadership Team.

ROLES AND RESPONSIBILITIES

• Supervisors: Develop and implement testing plans based on this guidance.

• Bureau/Office Safety and Health Managers: Assist local supervisors with development
and implementation of COVID-19 testing plans.
• Bureau Director/Bureau Assistant Secretary: Review and sign plans
• Bureau Emergency Management Coordinator: Submit plan to DOI Watch Office for
DOI COVID Leadership Team review.
• Office of Occupational Safety and Health: Provide updated guidance regarding type
and frequency of testing as needed. Assist DOI COVID Leadership Team with technical
review of submitted plans.
• Office of Human Capital: Provide guidance on medical records management.
• COVID Leadership Team: Review and approve testing plans submitted through DOI
Watch Office.