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A Complete Guide to Employee Health Screening for COVID-19

8-10 minute read

Michigan’s recent Executive Order (EO 2020-77 COVID-19), indicates that manufacturing companies must conduct daily entry screening protocols for workers, contractors, suppliers and any other individuals entering the facility. Under the Executive Order, various businesses are excluded from this requirement but are adopting this process as a safety measure for their employees. The risk and compliance experts at Axios HR have compiled a complete guide to COVID-19 employee health screening to help answer questions and provide guidance on key areas of concern. 

What is COVID-19 employee screening? 

Employee screening is the routine process of systematically reviewing each employee’s potential to carry or transmit COVID-19 based on observable or self-reported physical symptoms, an increased temperatureor their recent proximity to other potentially infected individuals.  

Why do employees need to be screened for COVID-19?

The most recent Executive Order (EO No. 2020-77 May 7, 2020) mandates that manufacturing facilities conduct a daily entry screening protocol for workers, contractors, suppliers and any other individuals entering their facilityEO No. 2020-77 defines screening protocols as follows: 

  1. Conducting a daily entry screening protocol for workers, contractors, suppliers, and any other individuals entering the facility, including a questionnaire covering symptoms and suspected or confirmed exposure to people with possible COVID-19, together with temperature screening as soon as no-touch thermometers can be obtained.
  2. Creating dedicated entry point(s) at every facility for daily screening and ensuring physical barriers are in place to prevent anyone from bypassing the screening.
  3. Suspending all non-essential in-person visits, including tours. 

Which industries are required to do COVID-19 employee screening? 

The screening protocols outlined in EO No. 2020-77 apply to “businesses or operations in the construction industry” and “manufacturing facilities.” However, all employers currently open for business can screen their employees, including small to large businesses, educational organizations and other employers.  

How should COVID-19 employee screening be conducted? 

Below is a list of basic recommendations for setting up access control, screening questions and temperature checking best practices. 

Access control 

  • Be cognizant of social distancing requirements for the employees waiting to have their temperatures checked. 
  • Consider whether additional shifts can be established to reduce the number of employees in the worksite at one time. 
  • Stagger the starting and ending times for shifts when possible (while still ensuring safe operations), to prevent employees from congregating during the shift change-over, and from over-crowding at entrances and exits. 
  • Create corridors (outside, but preferably covered in case it rains) where employees can enter the facility through a temperature-checking line. 
  • Have multiple lines to reduce crowding, if possible. 
  • Consider placing markings (with tape) on the ground in the corridor to demarcate six (6)-foot lengths to provide for social distancing by employees while in line. 

What questions are typically asked?

Below are examples of screening questions that can be used by any employer to effectively screen for COVID-19 symptoms: 

1. Do you have any of the following?  
  • Fever  
  • Shortness of breath (not severe) 
  • Cough  
  • Chills  
  • Repeated shaking with chills  
  • Muscle pain  
  • Headache  
  • Sore throat   
2. Are you ill, or caring for someone who is ill?
 
3. Have you had contact with someone diagnosed with COVID-19? 

 

What questions should you not ask?  

Nothing should be asked about an employee’s personal health history as this could cause disclosure of HIPAA-protected information.

What equipment is needed? 

According to EO No. 2020-77, screening should be conducted with touchless (temporal) forehead thermometers. Employees can submit responses to the screening questions verbally to be recorded by whoever is conducting the screening, or through an electronic application (as available).  

Employers should also consider PPE and other protective equipment needed to create a safe environment for anyone conducting the employee screening processes (e.g. plexiglass barriers, etc.).  

Should we screen all visitors? 

Manufacturing facilities must conduct daily entry screening protocol for contractors, suppliers and any other individuals entering the facility, which includes a questionnaire and temperature screening.     

All visitors, suppliers and contractors, should be notified of your protocols prior to visiting your facility to prevent the spread of the virus.   

Non-critical in person visits should be suspended. Businesses and operations that require in-person visitors critical to operations should follow their COVID-19 preparedness and response plan supporting safe distancing, limiting meetings. 

What should employers do with the information? 

Appropriate actions should be taken to protect other workers who are exhibiting symptoms. Therefore, it is important for employers to develop and follow their workplace policies and procedures to minimize the disease from spreading. For more information on developing a COVID-19 response plan, visit our article hereBest practices include the following:    

  • Employers should keep records of any worker who has been excluded from work due to failing a health screen.  
  • The employer needs to maintain the confidentiality of all information gathered including statements, logs, temperature checks and questionnaires.  
  • All information about a particular employee must be stored separately from the employee’s personnel file.      

Currently, no federal or state agency has recommended or mandated employers store or maintain health screenings for a specific period of time. If an employee tests positive for COVID-19 the healthcare provider that receives the confirmation of a positive test result is a mandatory reporter who will handle the reporting responsibility. 

What happens if we decide to not test employees for COVID-19? 

Under EO No. 2020-77 employers could be subject to sanctions to the fullest extent of the law. 

How long will business be required to screen employees? 

Currently, no state agency has provided a timeframe on when this process will be discontinued.

How often do employees need to be screened? 

  • Is it only at the beginning of each shift? 
    • Employees should be tested prior to starting their first shift of the day.
  • What if they leave the premises during a break? 
    • There are no guidelines to support the need to retest employees if they leave the premises for break or lunch.  

Can employee health screening for COVID-19 be outsourced? 

Yes, for more information please inquire about Axios HR’s Workplace Health Screening services. Advantages of using a 3rd party screening system include a standardized, expedited process and single point of control for health information. If a 3rd party vendor is utilized, ensure that the provider is using compliant processes and coordinating with all required internal departments accordingly.

What employee handbook changes should be made regarding health screening? 

The ADA requires that any mandatory medical test of employees be “job related and consistent with business necessity.” Applying this standard to the current circumstances of the COVID-19 pandemic, employers may take steps to determine if employees entering the workplace have COVID-19 because an individual with the virus will pose a direct threat to the health of others.  

Therefore, an employer may choose to administer COVID-19 testing to employees before they enter the workplace to determine if they have the virus.  

No employee waiver or addition to an employee handbook is needed to screen employees as companies are not asking for any confidential medical information. 

For more information on our Workplace Health Screening services, contact us here.   

Date

May 19, 2020

Author

Axios HR

Category

> 50 employees < 50 employees Article Business Executives Business Owners Business Owners Over 50 Employees Compliance HR Professional HR Professionals Over 50 Employees Human Resources

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