June 1, 2020

On May 29, 2020, the Centers for Disease Control and Prevention (“CDC”) updated its Interim U.S. Guidance for Risk Assessment and Work Restrictions for Healthcare Personnel with Potential Exposure to COVID-19.  To prevent the spread of COVID-19, CDC recommends occupational health programs have a low threshold for evaluating symptoms and testing healthcare personnel (“HCP”) and a conservative approach to HCP monitoring and applying work restrictions.     

What does the interim guidance focus on?

CDC’s interim guidance focuses on exposures that would result in higher risk to HCP, such as prolonged exposure to patients with COVID-19 when HCP’s eyes, nose, or mouth are not covered. However, specific factors associated with exposures should be evaluated on a case by case basis.  Interventions, including work restrictions, can be applied if the risk for transmission is substantial.  Work restrictions might also be applied to HCP exposed to a person under investigation (“PUI”) if test results for the PUI are not expected to return within 48 to 72 hours.  CDC recommends maintaining a record of HCP exposed to PUIs.  If test results are delayed more than 72 hours or the patient is positive for COVID-19, then work restrictions should be applied.

What are the work restrictions for HCP who had a prolonged close contact with a patient, visitor, or HCP with confirmed COVID-19?

HCP who had prolonged close contact with a patient, visitor, or HCP with confirmed COVID-19 and who did not wear: (a) a respirator or facemask, (b) eye protection if the person with COVID-19 was not wearing a cloth face covering or facemask, or (c) gown, gloves, eye protection, and a respirator while performing an aerosol-generating procedure should:

• Be excluded from work for 14 days after the last exposure;
• Be advised to monitor themselves for fever or symptoms consistent with COVID-19; and
• Contact their established point of contact to arrange for medical evaluation and testing if fever or symptoms consistent with COVID-19 develop.

Are there work restrictions for HCP who have not had prolonged close contact with a patient, visitor, or HCP with confirmed COVID-19?

No, however, HCP should adhere to all recommended infection prevention and control practices, including wearing a facemask while at work, undergoing active screening for fever or symptoms consistent with COVID-19 at the beginning of their shift, monitoring themselves for a fever or symptoms consistent with COVID-19, and not reporting to work when ill. Any HCP who develops a fever or symptoms consistent with COVID-19 should immediately self-isolate and contact their established point of contact to arrange for medical evaluation and testing.

What is the time period when a patient, visitor, or HCP with confirmed COVID-19 could be infectious?

For individuals with confirmed COVID-19 who developed symptoms, the exposure window should be two days before symptom onset through the time when the individual meets the criteria for discontinuation of transmission-based precautions.  Individuals with confirmed COVID-19 who never developed symptoms should be considered potentially infectious beginning two days after their exposure until they meet criteria for discontinuing transmission-based precautions.  If the date of exposure is unknown, it is reasonable to use a starting point of two days prior to the positive test through the time period when the individual meets criteria for discontinuation of transmission-based precautions for contact tracing.     

How does the CDC define “prolonged,” “close contact” and “fever”?

“Prolonged” is defined as a time period of 15 or more minutes.  However, if the exposure occurs during performance of an aerosol-generating procedure, any duration should be considered “prolonged.”

“Close contact” is defined as being within six feet of a person with confirmed COVID-19 or having unprotected direct contact with infectious secretions or excretions of the person with confirmed COVID-19. 

A “fever” is defined as either the measured temperature >100.0 ^oF or a subjective fever.  Fever may be intermittent or may not be present in some patients.

Has the Texas Department of State Health Services provided any guidance for HCP exposed to COVID-19?

Yes, the Texas Department of State Health Services has developed resources for symptomatic or asymptomatic HCP with confirmed or probable cases of COVID-19.  Upon returning to work, HCP should:

• Wear a facemask at all times while in the healthcare facility until all symptoms have completely resolved.  After this time period has passed, HCP should revert to their facility policy regarding universal source control during the pandemic;
• Adhere to hand hygiene, respiratory hygiene, and cough etiquette per the CDC’s interim infection control guidance; and
• Self-monitor for symptoms and seek reevaluation from occupational health if respiratory symptoms recur or worsen.

Please note that COVID-19 guidance is changing and/or being amended regularly.  As always, we are available to advise and assist you at every turn.