Health Care Personnel TB Screening Resources
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.
August 31, 2021
CDC is posting new recommendations about COVID-19 vaccination and the timing of immune-based tests for tuberculosis infection, such as the TST and IGRA, on its COVID-19 website (at https://www.cdc.gov/vaccines/covid-19/clinical-considerations/covid-19-vaccines-us.html):
“COVID-19 vaccination should not be delayed because of testing for TB infection. Testing for TB infection with one of the immune-based methods, either the tuberculin skin test (TST) or an interferon release.
American College of Occupational and Environmental Medicine (ACOEM) Guidance Statement: Tuberculosis Screening, Testing, and Treatment of Health Care Personnel, ACOEM and NTCA Joint Task Force on Implementation of the 2019 MMWR Recommendations
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
The Licensing and Certification program has sent out an All Facilities Letter on 9/8/21 that extends the suspension of the Professional Certification Requirements for Certified Nurse Assistants (CNAs) until Dec 31, 2021. This includes the TB testing requirement.
Please see link: https://www.cdph.ca.gov/Programs/CHCQ/LCP/Pages/AFL-20-35.aspx
Previously posted, 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:
CalOSHA August 13, 2020 Update
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,