Know the Rules

Pre-Work Employee Health Screening and Symptom Checks

State Database
CDC Recommendations for Pre-Work Employee Health Screening

The CDC recommends that every business conduct daily health checks before they enter the facility

The CDC also asks that employers consider conducting daily in-person or virtual health checks (e.g., symptom and/or temperature screening) of employees before they enter the facility, in accordance with state and local public health authorities and, if available, your occupational health services:

  • If implementing in-person health checks, conduct them safely and respectfully. Employers may use social distancing, barrier or partition controls, or personal protective equipment (PPE) to protect the screener. However, reliance on PPE alone is a less effective control and is more difficult to implement, given PPE shortages and training requirements.
  • See the “Should we be screening employees for COVID-19 symptoms?” section of General Business Frequently Asked Questions - see here for the link (this may open a new tab in your browser)
  • Complete the health checks in a way that helps maintain social distancing guidelines, such as providing multiple screening entries into the building
  • Follow guidance from the Equal Employment Opportunity Commission (EEOC) regarding confidentiality of medical records from health checks.
  • The CDC also urgest that business prevent stigma and discrimination in the workplace, by making employee health screenings as private as possible. And of course emphasizing that employers should not make determinations of risk based on race or country of origin and be sure to maintain confidentiality of each individual’s medical status and history.


The CDC views screening employees as an optional strategy that employers may use. Performing screening or health checks will not be completely effective because asymptomatic individuals or individuals with mild non-specific symptoms may not realize they are infected and may pass through screening. Screening and health checks are not a replacement for other protective measures such as social distancing.

Impact of HIPAA and ADA on Pre-Work Employee Health Screening

HIPAA imposes obligations to safeguard protected health information (PHI) only on covered entities. Covered entities include health plans, health care clearinghouses, and health care providers. Employers acting in their capacity as an employer is not subject to HIPAA. For HIPAA it is important to understand that: However, the Americans with Disabilities Act (ADA) or state confidentiality laws, may apply.

  • HIPAA defines “Covered Entities” to generally include health care providers, health plans, and health care clearinghouses.
  • Covered Entities may not disclose protected health information (“PHI”) unless permitted by HIPAA. An individual’s health status related to testing positive for COVID-19 is considered PHI.
  • Unless an employer is otherwise a Covered Entity as described above, it is not subject to HIPAA’s restrictions on disclosures of PHI.

While it seems most businesses can screen employee health without violating HIPAA, the Americans with Disabilities Act (ADA) or state confidentiality laws, may apply.

For instance, the ADA requires employers that obtain medical information through inquiry or examination to maintain it in a confidential medical file and keep it separate from the employee’s personnel file. Employers have been encouraged by the CDC and EEOC to question their employees regarding travel, exposure, or symptoms related to COVID-19. Any medical information disclosed as part of this dialogue should be treated as confidential. Many employers have opted for pencil and paper forms for mandated employee health screenings. But they may be inadvertently mishandling protected information under the ADA.

If a positive case is identified in the workplace, the employer is encouraged to investigate the exposure of others in the workplace without disclosing the name of the individual or any personally identifiable information about the person. ADA prohibits the employer from disclosing the identity of a person with a positive tests.

Employee Health Screening and Assessment Rules by State

Alabama

Recent Notice

Health Screening Summary

Employers should screen their employees with questions related to COVID-19 symptoms and potential exposures before they report to and enter the workplace. Employers should also take the temperature of each worker with a no-touch thermometer each day when they arrive at work, or ask their employees to take their own temperatures prior to work, to confirm their temperatures are not higher than 100.4°F. Here are other recommendations that all businesses are strongly encouraged to follow:

Allow employees to work from home as much as possible

Screen all employees reporting to workforce COVID-19 symptoms with the following questions:
- Have you been in close contact with a confirmed case of COVID-19?
- Are you experiencing a cough, shortness of breath or sore throat?
- Have you had a fever in the last 48 hours?
- Have you experienced new loss of taste or smell?
- Have you experienced vomiting or diarrhea in the last 24 hours?

Screen employees for fever: Best practice: employers should take temperatures onsite with a no-touch thermometer each day upon a person’s arrival at work. Minimum practice: an employee may take his or her temperature before arriving. In either case, a normal temperature does not exceed 100.4 degrees Fahrenheit

Direct any employee who exhibits COVID-19symptoms, who answers yes to any of the screening questions or who is running a fever, to leave the premises immediately and seek medical care or COVID-19 testing or both.

Implement workplace cleaning and disinfection practices, according to CDC guidelines, with regular sanitization of often-touched surfaces at least every two hours.

Post extensive signage on health policies, including the following documents, in the workplace:
- CDC guidance to stop the spread of germs, at https://www.cdc.gov/coronavirus/2019-ncov/downloads/stop-the-spread-of-germs.pdf
- CDC guidance on Symptoms of COVID-19, at https://www.cdc.gov/coronavirus/2019-ncov/downloads/COVID19-symptoms.pdf

Alaska

Recent Notice

Health Screening Summary

Employers re-opening businesses should conduct pre-shift symptom screening of their workers.

Business Responsibilities
All businesses should assist individuals with personal mitigation strategies including:
1. Opportunities for frequent hand washing
2. Maintaining opportunities for 6 foot distancing between all non-family members.a. This may include distanced tables, one way entrances, limited capacity services, and increased outdoor services.
3. Encourage face covering
4. Screening for people who are ill and limiting entrance to those who are healthy.
5. Regular cleaning and extra attention to high touch surfaces.
6. Special accommodations for those at higher risk to help minimize their risk.

Arizona

Recent Notice

Health Screening Summary

Employers must implement symptom screening for employees prior to the start of their shift, including temperature and wellness/symptom checks, as they arrive on premises or before opening. The state also provides guidance for specific industries. You can find that guidance in the link above. In total the following general protocols have been provided by the State of Arizona.

Keeping the Workplace Safe

- Educate employees about how they can reduce the spread of COVID-19
- Conduct temperature or wellness checks at the start of shifts to ensure employees do not exhibit COVID-19 symptoms (fever of greater than 100.4 F, cough, shortness of breath)
- Stagger work shifts so employees are not entering and leaving at the same time
- Create physical distancing measures for work areas such as separating seating arrangements by six feet
- Establish remote policies to have an inclusive culture for remote employees
- Limit large gatherings such as meetings and opt for virtual meetings
- Consider barriers such as plexiglass between employees and customers
- Use contactless payment options

Arkansas

Recent Notice

Health Screening Summary

Separate requirements issued for restaurants and gym/fitness centers require employers to screen staff for specified symptoms before they enter the workplace. The State has implemented phased recommendations across industries to screen their workers for fever, cough, shortness of breath, sore throat, or loss of taste or smell as they are entering the building at the beginning of the workday. Please access the link above for more details.

California

Recent Notice

Health Screening Summary

Requires all employers to train employees on how to limit the spread of COVID-19, including how to screen themselves for symptoms and stay home if they have them. Many local counties such as San Francisco and Los Angeles have implemented pre-work employee health screening and symptom checks. At minimum the State outlines the following protocols before reopening.

All facilities must:
-
Perform a detailed risk assessment and create a site-specific protection plan
- Train employees on how to limit the spread of COVID-19. This includes how to screen themselves for symptoms and when to stay home
- Set up individual control measures and screenings
- Put disinfection protocols in place
- Establish physical distancing guidelines

Colorado

Recent Notice

Health Screening Summary

The State requires employers to conduct daily temperature checks of their workers if feasible, or if not, to require employees to check their own temperatures at home.

The State also requires all employers to implement daily health screening of workers if feasible, or if not, to require their employees to self-assess at home prior to reporting to work, with additional requirements for businesses with 50 or more employees.

Best Practices for All Business:

- Deputize workplace coordinator(s) charged with addressing COVID-19 issues
- Maintain 6-foot distancing when possible, and discourage shared spaces
- Frequently sanitize all high-touch areas
- Post signage for employees and customers on good hygieneEnsure proper ventilation
-Avoid gatherings (meetings, waiting rooms, etc) of more than 10 peopleImplement symptom monitoring protocols (including workplace temperature monitoring and symptom screening questions) where possible
- Best practice is to implement a temperature check station at the entrance to the business. If this is not feasible, employee will check for symptoms at home and report symptoms either electronically or on paper per the system created by the business.
- Eliminate or regularly sanitize any items in common spaces (i.e., break rooms) that are shared between individuals (i.e., condiments, coffee makers, vending machines) 
- Provide appropriate protective gear like gloves, masks, and face coverings and encourage appropriate use.

Connecticut

Recent Notice

Health Screening Summary

Recommends that employees take their own temperature at home and not report to work if their temperature exceeds 100.4°F. Separate orders for personal care services, retail restaurants and office-based businesses require employers screen employees resuming to on-premises work to confirm they have not experienced COVID-19 CDC-defined symptoms, as further described in the orders.

The State provides general policies for Essential Employers including rules for symptom checking site visitors and guests. The State also has a policy that all businesses must self-certify ahead of re-opening. You can find the policies in the link above.

Delaware

Recent Notice

Health Screening Summary

Delaware requires high-risk businesses (as defined within the order) to either institute a self-reporting policy for their employees for any body temperatures at or above 99.5°F, or do temperature screening on site.

High-risk businesses must also screen each incoming employee with a questionnaire containing health questions indicated within the order.

- Businesses are responsible to follow the Responsibilities for all Businesses, set forth in the State of Emergency Order

-
Employers must enforce strict social distancing protocols.

- Employees and customers have a responsibility to self-quarantine if they have a reason to expect that they may be ill with or may have come into contact with COVID-19. Employees who are symptomatic must not physically return to work until cleared by a medical professional.

- Employers are encouraged to continue teleworking. Employees who have been working from home throughout this crisis should continue working from home unless there is a substantive change to business operations in Phase 2 (e.g. a business was closed, but now it’s open).

- All surfaces touched by customers, including doors, restrooms, and POS infrastructure must be disinfected using an EPA-approved disinfectant every 15 minutes to 2 hours.

- Hand sanitizer must be used by employees at frequent intervals during any service, appointment or scheduled event, including at a minimum after contact with surfaces touched by others, after incidental contact with a patron or visitor, and before preparing or distributing food or drink.

- Employees must social distance from each other while working. This can be accomplished through spacing or moving workstations, staggering shifts or other means.

- Businesses must make hand sanitizer or handwashing stations readily available for all employees, patrons, and visitors throughout the business’ location, including at each entry and exit at a minimum.

-Hand sanitizer must be composed of at least 60% ethanol or 70% isopropanol.Employers must post signs on stopping the spread of COVID-19, hand hygiene and wearing cloth face covering.

Florida

Recent Notice

Health Screening Summary

There are no statewide orders or recommendations, but many localities have issued provisions regarding temperature and health screenings.

Georgia

Recent Notice

Health Screening Summary

Recent Notice
Governor of Georgia issues an order that requires employers in restaurants, bars, retail food establishments, gyms, fitness centers, bowling alleys, personal care services, and all other non-critical businesses conducting in-person operations screen and evaluate employees who exhibit signs of illness, such as a fever over 100.4°F, cough, or shortness of breath.

Employers must require employees who exhibit signs of illness to seek medical attention and not report to work. The same order also requires gyms and fitness center to screen patrons at the facility entrance and turn away any displaying COVID-19 symptoms.

Individual localities such as Cobb County and the City of Atlanta rules for re-opening may vary.

Hawaii

Recent Notice

Health Screening Summary

None available.

Idaho

Recent Notice

Health Screening Summary

The State has established a protocol to maintain a six (6) foot physical distancing requirement for employees and patrons.  In addition, Idaho has provided protocols for how a business will provide adequate sanitation and personal hygiene for employees, vendors and patrons.

Along with identifying how the business will provide services limiting close interactions with patrons such as, but not limited to:

- Online, digital or telephonic ordering,
- Curbside pickup delivery
- Establishing hours of operations for vulnerable populations
- Limiting numbers of patrons in the business at a time
- Directing the flow of traffic in the business
- Use of signage and barrier protection to limit movement and maintain distancing

Identify strategies for addressing ill employees, which should include requiring COVID-19 positive employees to stay at home while contagious and may include restricting employees who were directly exposed to the COVID-19 positive employee, as well as the closure of the facility until it can be properly disinfected.

Businesses may on a case-by-case basis, include other practices such as screening of employees for illness and exposures upon work entry, requiring non-cash transactions, etc.

Illinois

Recent Notice

Health Screening Summary

Minimum Guidelines: 

1. Employers should make temperature checks available for employees and encourage their use. Employers should post information about the symptoms of COVID-19 in order to allow employees to self-assess whether they have any symptoms and should consider going home

2. All employers should have a wellness screening program. Resources outlining screening program best practices are posted on the DCEO Restore Illinois website a. Employer should conduct in-person and mid-shift screening of employees upon entry into workplace to verify no presence of COVID-19 symptoms

3. If employee does contract COVID-19, they should remain isolated at home for a minimum of 10 days after symptom onset and can be released after feverless and feeling well (without fever-reducing medication) for at least 72 hours OR has 2 negative COVID-19 tests in a row, with testing done at least 24 hours apart

4. If an employee is identified as being COVID-19 positive by testing, CDC cleaning and disinfecting should be performed as soon after the confirmation of a positive test as practical

5. Where appropriate, notify employees who have been exposed

6. Any employee who has had close contact  with co-worker or any other person who is diagnosed with COVID-19 should quarantine for 14 days after the last/most recent contact with the infectious individual and should seek a COVID-19 test at a state or local government testing center, healthcare center or other testing locations.

All other employees should be on alert for symptoms of fever, cough, or shortness of breath and taking temperature if symptoms develop

Indiana

Recent Notice

Health Screening Summary

All Indiana businesses should take measures and institute safeguards to ensure a safe environment for their employees, customers, and clients.  These include employee screening procedures. 

Back On Track Indiana recommends: 

- Conducting daily health assessments by utilizing a screening procedure for COVID-19 symptoms for employees who are reporting for work. Examples include self-assessments before arrival in the workplace, screening questions, or taking temperatures with a no-touch thermometer. 

- Have a plan in place if an employee presents symptoms.

Resources for testing are available in Indiana through medical providers and the OptumServe testing procedure.

Iowa

Recent Notice

Health Screening Summary

The State of Iowa protocols require businesses to post signage at the door indicating no one should enter the establishment (including employees) if they currently have symptoms or have been around anyone with a confirmed COVID-19 diagnosis in the last 14 days.

Businesses should continue to follow the CDC’s guidance for businesses and ensure return to work policies for employees with positive diagnoses are consistent with CDC guidance regarding self isolation.

The CDC guidelines recommends that business considering conducting pre-work screening for their employees.

Kansas

Recent Notice

Health Screening Summary

Kansas department of Health and environment recommends that you pre-screen employees for symptoms.

Protocols ask that businesses monitor temperatures and symptoms regularly, issue or approve personal face coverings, maintain social distancing and clean and disinfect regularly.

Kentucky

Recent Notice

Health Screening Summary

The State requires that employees undergo health survey screening and daily temperature checks.

Businesses may choose whether to require on-site temperature screenings, or self-screenings conducted by employees at home at least once every 24 hours, ideally just before going to work, and reported to the employer prior to beginning work.

Employees with a fever above 100.4°F should not report to work.

Minimum Requirements:
- Enforce Social Distancing (six (6) feet or more)
- Universal face coverings
- Provide Adequate Hand Sanitizer and Encourage Hand Washing
- Ensure Proper Sanitation
- Conduct Daily Temperature/Health checks


Louisiana

Recent Notice

Health Screening Summary

Louisiana Department of Health recommends that employees who have symptoms of acute respiratory illness are recommended to stay home and not come to work until they are free of fever (100.4° F [37.8° C] or greater using an oral thermometer), signs of a fever and any other symptoms for at least 24 hours, without the use of fever-reducing or other symptom-altering medicines (e.g. cough suppressants).

Employees should notify their supervisor and stay home if they are sick. Ensure that your sick leave policies are flexible and consistent. The most recent guidelines appear to be from February 2020

Maine

Recent Notice

Health Screening Summary

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