The Minnesota Department of Health (MDH) shared updated information this week on the issue of whether a healthcare worker who experiences a high risk exposure to COVID-19, but who is asymptomatic and has not tested positive for the virus, may return to work prior to the end of his or her 14-day quarantine if staffing needs are acute. The information is consistent with prior guidance from MDH, but we want to be sure members have access to the latest published standards on this and on the related issue of asymptomatic staff who have tested positive.

Providers Must Exhaust All Other Options Before Considering the Return of Quarantined Healthcare Workers

MDH’s COVID-19 Recommendations for Health Care Workers (revised 11/23/2020) states that health care facilities experiencing acute staffing shortage must exhaust all other options (e.g., reducing non-time sensitive procedures) to obtain staff prior to considering the return of healthcare workers (HCW) who are in quarantine after experiencing a high-risk exposure to a person with COVID-19, as long as these workers are not experiencing symptoms and are not infectious (i.e., have not recently tested positive) with COVID-19. If bringing these workers back, the facility should follow these standards:

• Worker protections are established in state statute, and HCW who have experienced a high-risk exposure cannot be forced to return to work during the quarantine period. If HCW choose not to return to work, Minnesota Statutes, section 144.4196 protects them from retaliation.
• Different types of high-risk exposures carry different risks of testing positive for COVID-19. Therefore, facilities should ask exposed HCW to return to work in the following order. All HCW from one group should be asked to return prior to bringing back HCW from the next group: (1) HCW with high-risk exposure to a patient, resident, or coworker; (2) HCW with high-risk exposure to a social contact; (3) HCW with high-risk exposure to a household member; HCW with a household exposure should only return if able to isolate from the positive household member.
• Exposed HCW who return during quarantine should take on a role that does not have direct patient care duties (e.g., telemedicine, phone triage), when feasible. If it remains necessary for the HCW to provide direct patient care during the quarantine period, the HCW should:
  • Avoid seeing high-risk patients (e.g., older adults, immunocompromised people, and those with comorbidities), if possible.
  • Practice diligent hand hygiene and wear a medical-grade face mask at all times.
  • Avoid sharing breakroom or lunch room with coworkers.
  • Monitor themselves closely for any symptoms associated with COVID-19 (e.g., measured or subjective fever, cough, shortness of breath, chills, headache, muscle pain, sore throat, or loss of taste or smell), and measure body temperature daily before going to work.
  • Remain at home and notify their supervisor if they develop respiratory symptoms OR have a measured body temperature of greater than 100 degrees Fahrenheit.
  • If at work when fever or respiratory symptoms develop, immediately notify their supervisor and go home.
  • Notify their supervisor of other symptoms (e.g., fever greater than 100 degrees Fahrenheit, nausea, vomiting, diarrhea, abdominal pain, runny nose, fatigue), as medical evaluation may be recommended.
• HCW who have had a high-risk exposure and return to work during quarantine should be proactively tested post-exposure (e.g., on days 3, 5, 7, 10, and 12) (updated recommendation).
• Facilities should conduct additional mid-shift screening for signs and symptoms of COVID-19 for all HCW working during quarantine (updated recommendation).
• Facilities should increase audits for PPE, hand hygiene, and activity in breakrooms and lunch rooms and limit the number of HCW in breakrooms to ensure social distancing. HCW working during a quarantine period should take breaks alone in the breakroom, if possible (updated recommendation).
• Facilities should establish a higher level of awareness for potential SARS-CoV-2 spread within the facility, following recommendations from MDH for assessment of clusters of individuals (patients, residents, health care workers) who have symptoms or have tested positive. Maintain a low threshold for investigating increases in staff calling in sick and for observing fatigue in using personal protective equipment in areas such as break rooms.

MDH has confirmed previously that facilities do not need approval from the State Emergency Operations Center (SEOC) to call back staff who do not have symptoms but have experienced a high-risk exposure and have not tested positive for COVID-19. MDH staff are available for consultation if a provider is making a risk assessment about this staffing option, but formal approval is not required.

Bottom line: Asking back a healthcare worker who experiences a high risk exposure to COVID-19, but who is asymptomatic and has not tested positive for the virus, is an option that employers may consider when other options have been exhausted and staffing needs are acute. However, providers should follow the State’s guidance, carefully evaluate the risks involved, and carefully document the decision-making process followed if going this route.

Providers May Not Use Asymptomatic Staff Who Have Tested Positive for COVID-19 Without Approval from MDH

MDH’s Clarification of Staffing Options for Congregate Care Facilities Experiencing Staff Shortages (revised 10/13/2020) states that facilities must work with the State Emergency Operations Center (SEOC) to demonstrate that the facility is having a recognized staffing crisis and must obtain approval from the MDH Commissioner before HCW who do not have symptoms but have tested positive for COVID-19 can be asked to continue working or to return to work earlier than MDH and CDC guidance dictates. Criteria for meeting an acute staffing crisis and requirements for documentation are outlined in Defining Crisis Staffing Shortage in Congregate Care Facilities: COVID-19 and include:

• The facility has activated its contingency staffing plan and has exhausted all options to address staffing needs, triggering a crisis level of staffing.
• The facility has exhausted all options to cohort COVID-19-positive residents internally or transfer positive residents to COVID-19 care sites.
• The only remaining approach to ensure adequate resident care and safety is to evacuate the facility.

If the facility is designated to be in an acute staffing crisis by the SEOC, the MDH Commissioner may grant the facility the ability to allow asymptomatic HCW positive for COVID-19 to return to work in roles that include direct care for residents with confirmed COVID-19. Positive HCW cannot provide direct care or interact with residents or staff who have not been diagnosed with COVID-19. Ill or symptomatic COVID-19-positive staff should never enter the facility. The criteria above must be met and approval from the MDH Commissioner must be given before allowing asymptomatic staff with confirmed COVID-19 to work.

Please contact Jon Lips or Kari Everson if you have any questions about these standards.