Planning for your employees’ return to physical work locations? Return-to-work planning is generally focused on reducing the risk of transmission among employees, and one proposal being widely marketed to employers is return-to-work COVID-19 testing for employees.
Wellmark Blue Cross and Blue Shield is committed to helping employers understand the types of tests available, their efficacy and limitations, and the situations in which the tests are covered.
What tests are available to detect COVID-19?
|Type of tests||PCR/Antigen testing||Antibody testing (serological tests)|
|Purpose of test||To detect active COVID-19 infections||To defect the presence of antibodies indicating a past infection|
How reliable are these tests?
Although the tests are important to monitoring the virus’ impact on public health, and are especially important for detecting previous infections with few or no symptoms, there are limitations:
- They aren’t always accurate.
- PCR/antigen tests are generally very accurate when the test result is positive. However, false negatives are a known issue for PCR and antigen tests.
- Accuracy for antibody tests varies widely.
- Significant concerns have been raised regarding both false positives and false negatives being produced by these tests.
- Additionally, the accuracy of antibody tests is dependent on the number of people in the population who have had a COVID-19 infection. The CDC has suggested External Site that almost half of all “positives” would be false positives and that a second test would be needed to confirm a positive result.
- According to the CDC External Site, “[s]erologic test results should not be used to make decisions about returning persons to the workplace.”
- Timing is everything to get an accurate result.
- PCR/antigen tests done too early in an infection may mean there are not enough pathogens in the sample to produce a “positive” result.
- Similarly, antibody testing done too early post-infection may produce a “negative” result, as antibodies generally don’t appear for 1 to 3 weeks after an infection.
- Test results represent a snapshot in time.
- An individual’s infection status can change between the time the test sample is collected and when the test results are received. Without other precautions being taken like requiring masks, a newly-infected employee could infect a number of other employees in a matter of hours.
Any concerns with antibody tests?
To date, very few antibody tests have been validated and authorized by the FDA.Hundreds of antibody tests have flooded the market in recent months before obtaining Emergency Use Authorization from the FDA, with many being marketed inappropriately or performing poorly on accuracy and sensitivity standards.
Often, they cannot zero-in on COVID-19.Antibody tests may not be sensitive enough to distinguish between COVID-19 and other types of coronavirus (including four types of these viruses that cause the common cold and circulate widely).
The jury is still out on whether antibodies equal immunity.According to the World Health Organization, there is currently no evidence that people who have recovered from COVID-19 and have antibodies are protected from a second infection. Without evidence confirming that antibodies provide immunity (and the length of such immunity), antibody tests may provide a false sense of security for the employer and employees.
When are PCR/Antigen and antibody tests covered?
Individual tests to determine current or past infection are covered
As required by the Families First Coronavirus Response Act and the Coronavirus Aid (CARES), Relief and Economic Security Act, PCR/antigen and antibody testing to determine current or past infection is covered on an individual basis, as determined by the member’s health care provider for the member’s health purposes.
Return-to-work testing is not covered by your health plan (Fully-Insured1)
Evaluating a person’s ability to return to a physical work location through PCR/antigen and/or antibody testing as part of an employer’s return-to-work strategy is not a health plan benefit for fully-insured health plans. For a return-to-work testing strategy to be effective, employers would need to test all employees, including those who chose not to participate in the employer’s health plan and those who may not be eligible to participate in the employer’s health plan, such as part-time employees. Additionally, health plan benefits must be available to all participants, including enrolled spouses and dependents. Given the mismatch between the group, an employer would need to test (its employees) and the participants under the employer’s health plan, as well as return-to-work testing being driven by the employer for employment purposes, return-to-work testing is not payable as a health plan benefit.
Employers who still wish to pursue a return-to-work strategy that involves either PCR/antigen or antibody testing should consult their employment and/or benefits attorney for their options, including the potential for including such testing as part of an Employee Assistance Program, and will be responsible for direct payment of any testing expenses.
Self-funded2 health plans should carefully evaluate the risks of using health plan assets to pay for return-to-work testing
Self-funded health plans are likely to have the same mismatch within their workforce. An employer would need to test for an effective return-to-work testing strategy (all of its employees, regardless of whether the employee chose to or was eligible to participate in the health plan) and the participants under the employer’s health plan (which includes spouses and dependents). As a result, return-to-work testing strategies will be focused on employment status, not health plan participation status.
Self-funded health plan assets are intended to be used for the diagnosis and treatment of a plan participant’s health condition, and a self-funded health plan should carefully evaluate the risks of using plan assets for non-participants, as well as making benefits available to only a subset of health plan participants.
Additionally, confidentiality restrictions usually prevent participant health information from being used by a participant’s employer, absent a specific exception or authorization to do so, and self-funded health plans should consult their employment and/or benefits attorney to fully understand plan documentation and notice requirements and any other fiduciary considerations.
Employers who still wish to pursue a return-to-work strategy that involves either PCR/antigen or antibody testing should work with their employment and/or benefits attorney to appropriately structure their testing strategies. Consistent with recent U.S. Department of Labor Guidance, one option may be using an Employee Assistance Program for such testing.
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- 1 With a fully insured plan, the risk falls on the health insurance company. The employer pays a fixed premium to an insurance carrier that then covers the claims.
- 2 With a self-funded plan, the person or company assumes the risk by covering the majority of the health claims themselves. Self-funded plans pay for medical claims and fees out of their general assets, basically acting as insurers.