Return to Work Safely: Screening for Employees in COVID-19

States across the nation are re-opening. Now businesses are challenged to help ensure that the workplaces that their valued employees return to work safely and customers will be populating are safe.


A myriad of issues must be addressed to ensure compliance with applicable regulations:

First, management must create a policy that defines the organization’s goals to help ensure that the workplace, employees, and customers are kept virus-free during this and future pandemics (for more detail, please refer to the CDC’s guidelines):

Prospective, furloughed, or current employee?

When considering bringing employees back on board, distinguish between current employees and furloughed employees. They may be treated differently.

An employer may not ask a prospective employee about symptoms nor take their temperature until a conditional offer of employment is offered or a furloughed employee is directed to return to work. If a candidate for a furloughed employee is exhibiting symptoms or has an elevated temperature, the employer may either delay the start date or rescind the conditional offer of employment or return to a work order.

For current employees, employers may ask if they are experiencing symptoms of COVID-19. This can be done when employees enter the office or begin their shifts. They can be asked to complete a simple questionnaire. If the employer keeps these COVID-19-related inquiries, they must be treated as confidential medical information.

It is permissible for employers to take the temperatures of employees before entering the workplace and, ideally, at regular intervals throughout the day. Logs of temperatures must also be treated as confidential medical information.

Policies regarding questionnaires and taking of temperatures must be applied uniformly to all employees, at every level of the organization. Organizations that create a written policy stating that the employer has initiated these practices to help prevent the spread of an infectious disease in the workplace can prevent claims that the practices are not being uniformly applied or are in any way discriminatory, it may also help reassume staff that your company is doing everything possible to ensure their employees’ health, wellbeing, and welfare.

Screening Mechanisms 


Early in the pandemic, companies deployed respiratory illness symptom questionnaires as a mechanism to screen people for evidence of COVID-19. As employees are returning to their place of employment, symptom questionnaires remain a key mechanism to assure a safe return to work. If an employee states he/she had a fever or exhibited other typical COVID-19 symptoms, that information should be used to prevent the employee from returning to duty until after the symptoms resolve for a period of days. As with any other medical information, that questionnaire must be held as confidential information.

Organizations must be able to confidently separate the ill from the at-risk from the healthy. These questionnaires are easy to distribute and may be defensible. But while they may help, individuals may not have completed them honestly. An employee may have had a fever but not be infected by COVID-19. Obviously, additional and more reliable testing is required.

Testing for COVID-19

Viral and antibody tests

The type of test used by an organization may be decided by the company and how risk-averse they want to be.

According to the CDC, there are two kinds of tests that are available for COVID-19: viral tests (also referred to as antigen tests) and antibody tests.

An antibody test may not be able to show if you have a current infection, because it can take about one week after infection to make a detectable level of antibodies.

From a return to work testing perspective, there are three use cases for COVID-19 testing delineated below.

Viral (Antigen) Testing Alone

Testing for the specific evidence of COVID-19 is a feasible way to both screen employees in mass returning to work as well as test people who become symptomatic at work. This type of testing only reveals if the person has or does not have the virus at the same time as the test. It also does not predict if a person is immune or stratify them for future risk.

One use case for viral testing as a standalone screening mechanism is as follows:

Antibody Testing Alone

Antibody testing is a test that looks for an immune response triggered after being exposed to a virus-like COVID-19. These tests have received bad press since some of the original FDA-cleared tests were not specific for COVID-19, and these tests were cross-reactive with other known coronaviruses that have been infecting people for years. The antibody tests that have remained FDA approved/cleared are specific to COVID-19; therefore, these tests are excellent markers for COVID-19 exposure.

Antibody testing is conducted on blood samples. If a sample is positive for antibodies, it shows the person was exposed to and had an immune response to COVID-19. Antibody tests that are solely positive for the type of antibodies that appear at the end of an infection (Ig G) may convey the person is COVID-19 immune. IgG specific to certain makers in Hepatitis viruses is evidence of immunity; however, COVID-19 is a respiratory virus. Historically, influenza viruses tend to change (mutate) often leading to new outbreaks. Therefore, a person may be immune to COVID-19 but may be susceptible to COVID-21. People with mixed antibodies detected, still may be shedding virus thus, they are still considered infective.

A use case for antibody testing as a standalone screening program is as follows:

Comprehensive COVID-19 Testing Program

Leveraging the strengths of antibody and viral antigen testing provides employers with the most robust testing solution for COVID-19. Antibody tests look for exposure, and antigen test looks for infectivity. Looking at staging these two tests affords a company a program that provides objective proof of immunity status and infectivity.

The use case for a blended comprehensive program looks something like this:

Any of the above types of testing is very objective and generally defensible. The type of program your organization may want is blessed with your company culture and risk mitigation strategy. With any screening program, the symptom questionnaire is the key. Having a mechanism to receive and review the questionnaire in a confidential manner is also important.

Final Considerations

Many individuals will want to continue practical social distancing, which will impact asking employees to stand in line to get tested. Many will not participate in large gatherings. Keep these concerns in mind when planning the distribution of questionnaires and testing. Management personnel should be employed to administer tests since the information they will be collecting must be maintained confidentially. Each must be properly trained.

Note that specific fields including healthcare may require more stringent testing and qualification.

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Published: May 21st, 2020