Health Screening of Staff at IHS-Operated Facilities During the COVID-19 Pandemic
|FROM:||Director, Indian Health Service|
|SUBJECT:||Health Screening of Staff at IHS-Operated Facilities During the COVID-19 Pandemic|
The purpose of this Special General Memorandum (SGM) is to inform all Indian Health Service (IHS) Staff that, in accordance with IHS Circular No. 20-14, it has been determined that there is a Business Necessity to protect Staff from the COVID-19 pandemic and that COVID-19 poses a Direct Threat that requires screening of IHS Staff. Based on guidance of the Centers for Disease Control and Prevention (CDC) and public health authorities as of March 2020, the COVID-19 pandemic presents a hazard to Staff. The CDC and public health authorities have acknowledged the threat of community spread of COVID-19. They issued precautions to slow the spread, such as the identification and self-isolation of individuals who test positive or show symptoms of COVID-19. The CDC and the Equal Employment Opportunity Commission (EEOC) have provided COVID-19 specific guidance, including:
- CDC, Coronavirus (COVID-19)
- CDC, General Business Frequently Asked Questions
- EEOC, What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws
In addition, HHS has issued guidance for Staff in the workplace. HHS Phased Return to Normal Operations – Implementation Guidance. [PDF]
Based on this and other COVID-19 guidance, the IHS has determined that screening staff for COVID-19 is a Business Necessity and that COVID-19 represents a widespread Direct Threat. IHS’s determination is based on: (1) the duration of the risk—the risk of COVID-19 continues several months after the declaration of the pandemic; (2) the nature and severity of the potential harm—some who are exposed will become extremely ill and may require hospitalization or even die; and (3) the likelihood and imminence of the potential harm—everyone who is exposed is at risk of getting COVID-19 (IHS Circular 20-14).
The threat of COVID-19 requires that the IHS implement screening policies and procedures for all Staff to reduce transmission among Staff and maintain healthy operations and a healthy environment. Consistent with the Business Necessity and the Direct Threat, as well as the HHS Phased Return to Normal Operations Implementation Guidance, all IHS Staff are required to:
- Wear a personal face covering that complies with CDC guidelines when entering any IHS facility and at all times while in a healthcare facility, including in breakrooms or other spaces where they might encounter others. All IHS Staff working in locations other than a healthcare facility must wear a cloth face covering in any congregate settings (e.g., shared office spaces or cubicles) and in common areas (e.g., breakrooms) where social distancing is difficult to maintain.
- If Staff become ill or symptomatic in the workplace, notify their supervisor and immediately leave the workplace (self-isolate); such Staff also are encouraged to contact their health care provider.
- Stay home if they are feeling ill or have been in close contact1 with someone who is sick.
- Notify their supervisor as soon as possible if they test positive for COVID-19.
In addition to these requirements, facility-specific COVID-19 screening policies and procedures shall be established. At a minimum, the facility-specific COVID-19 screening policies and procedures must be consistent with the requirements listed above. In addition, depending on the local and situational considerations, additional COVID-19 screening policies and procedures may be required at particular IHS facilities, including but not limited to requiring Staff to:
- Take a COVID-19 test before entering the workplace if the test is authorized for use by the Food and Drug Administration.
- Answer pre-screen questions and take temperature screenings.
- Adopt specific infection-control practices recommended by federal public health authorities and, to the extent applicable, state and local public health authorities.
- Wear personal protective equipment (e.g., gloves and gowns) designed to reduce the transmission of COVID-19.
- Provide a doctor’s note or other documentation certifying fitness to return to work after having symptoms or testing positive for COVID-19.
This SGM becomes effective on the date signed.
/Michael D. Weahkee/
RADM Michael D. Weahkee, MBA, MHSA
Assistant Surgeon General, U.S. Public Health Service
Indian Health Service
1 Close contact is defined as: a) being within six feet of a person with confirmed COVID-19; or b) having unprotected direct contact with infectious secretions or excretions of a person with confirmed COVID-19.