Health Care Personnel TB Screening Resources

Current CDC and National TB Controllers Association (NTCA) guidance for health care personnel (HCP) related to TB shared below recommend baseline TB screening for HCP at hire and then based on the risk assessed for their facility or job duties not only because they are HCP.  CTCA supports California moving into alignment with thse national recommendations because testing for TB is not protective.  Treating those with a risk for TB and a positive TB test is protective.  Keeping TB infection from developing into TB disease, which is often mis-diagnosed, delaying diagnosis,  is still life-threatening. Ten percent of those diagnosed with TB disease in California die with TB. Risks for TB among adults in California are listed in the Adult California Risk Assessment linked here. 

In California, Licensing and Certification (L&C Title 22) and CalOSHA (Title 8) still require routine repeat TB testing of HCP. Their requirements and modifications to these HCP TB requirements during the COVID-19 emergency response are linked below. 

February 2021, from the CDC:  Interim Clinical Considerations for Use of mRNA COVID-19 Vaccines Currently Authorized in the United States

they include: When a tuberculin skin test or interferon gamma release assay is required by policy:

  • A TST or IGRA to meet administrative requirements, (for example, for healthcare employment or for admission to long-term care), can be done prior to mRNA COVID-19 vaccination or at the same encounter. The mRNA COVID-19 vaccine should not be delayed because of testing for TB infection.
  • A TST or IGRA should be deferred until ≥4 weeks after the completion of mRNA COVID-19 vaccination. If testing requirements or policies cannot be modified for the COVID-19 pandemic to accept this delay in TST or IGRA testing, it should be understood that a false negative TST or IGRA cannot be excluded, and consideration should be given to repeating negative TST or IGRA tests at least 4 weeks after the completion of COVID-19 mRNA vaccination. If TST was the initial test, boosting could be a factor if the result of the repeat test is positive.

Licensing and Certification (L&C) 

California Code of Regulation (CCR) Title 22, Div. 5, Ch.1-12. CDPH Licensing & Certification enforces licensing requirements for hire & annual testing and notifies health care facilities of policy changes through All Facility Letters (AFLs). 

Primary Care Clinics:

TB testing on hire requirements were specifically delayed for Primary Care Clinics: H&S code 1226.1(s)(2): “tuberculosis test requirement for primary care clinic personnel at the time of employment is suspended until 60 days after the end of the declared emergency” https://www.cdph.ca.gov/Programs/CHCQ/LCP/Pages/AFL-20-30.aspx 

AFL 19-28: August 16, 2019, State of California—Health and Human Services Agency California Department of Public Health, Updated Centers for Disease Control Tuberculosis Screening Recommendations for Health Care Personnel (HCP) and Nationwide Shortage of Tuberculin Skin Test Antigens https://www.calhospital.org/sites/main/files/file-attachments/afl-19-28.pdf

Sample Program Flexibility Request

https://www.cdph.ca.gov/Programs/CHCQ/LCP/CDPH%20Document%20Library/AFL-19-28-Attachment-02.pdf

CNA FAQ: Due to the current state of emergency, a nurse assistant enrolled in an approved certification training program or competency evaluation program may provide patient care prior to having a test for tuberculosis infection. The nurse assistant shall complete the test for tuberculosis infection as soon as practicable but no later than 30 days after the expiration of the state of emergency.  (See AFL 20-35.1)

Health Care Workers are persons who work in a health facility, service or operation, or who have occupational TB exposure in public health services in connection with health care.

California Tuberculosis (TB) Testing Regulations for Health Care Facilities, Title 22 (T22) California Code of Regulation, by facility type:

https://www.cdph.ca.gov/Programs/CHCQ/LCP/Pages/AFL-18-19.aspx

AFLs 2020: https://www.cdph.ca.gov/Programs/CHCQ/LCP/Pages/LNCAFL20.aspx

CalOSHA August 13, 2020 Update

TABLE 1 – Mandated Surveillance Exams and Consideration of Temporary Delay due to COVID-19 Risks

physician or other licensed health care professional (PLHCP)

Initial (before placement) Screening for TB
PLHCP should ask about TB symptoms, and should weigh importance of prior negative TB tests, if any, and whether there are new risk factors since most recent prior negative test (per current CDC guidance); offer TST or IGRA, unless ALL of above indicate low risk.

Periodic (annual) Screening for TB

PLHCP should weigh facility prevalence of TB and personal TB risk factors (per current CDC guidance) in deciding to delay offering a periodic TB test. Annual education about TB symptoms and instructions to seek care for symptoms should not be delayed. 


CalOSHA Annual TB testing of Health Care Personnel Code

According to the California Code of Regulations, Title 8, Section 5199(h)(3), “…The employer shall make an assessment for latent tuberculosis infection (LTBI) available to all employees with occupational exposure. Assessment procedures shall be in accordance with applicable public health guidelines.

(A) TB tests and other forms of TB assessment shall be provided at least annually, and more frequently if applicable public health guidelines or the local health officer recommends more frequent testing. Employees with a baseline positive TB test shall have an annual symptom screen.

(B) The employer shall refer employees who experience a TB conversion to a PLHCP knowledgeable about TB for evaluation”.

This section is available at . If you need further assistance, please contact the nearest Cal/OSHA Consultation Service office,
http://www.dir.ca.gov/dosh/consultation_offices.html.