Case Investigation and Contact Tracing in Non-healthcare Workplaces: Information for Employers

CDC encourages employers to collaborate with health departments when investigating workplace exposures to infectious diseases, including COVID-19. Quick and coordinated actions, including case investigation and contact tracing, can prevent COVID-19 transmission and may lower the need for business closures.

Employers' involvement with the official health department case investigation or contact tracing process may vary. It will depend on the authorities, responsibilities, and capacities of their health departments; federal, state, and local laws and regulations; and the level of interest and capacity of the employer. Employers may consult with their company's human resources, legal, medical, and occupational safety and health guidance, policy and other resources to help them develop and implement their COVID-19 preparedness, response, and control plan.

CDC's Coronavirus Disease 2019 (COVID-19) Workplaces and Businesses webpage provides information to help businesses limit the spread of COVID-19 within the workplace. This document provides tips and considerations for how employers can partner with state, tribal, local, or territorial (STLT) health departments and work with their employees in these COVID-19 response efforts.

What employers should know about COVID-19 case investigation and contact tracing

COVID-19 is a nationally notifiable disease, and when diagnosed or identified, must be reported by healthcare providers and laboratories to STLT health departments. Health departments are responsible for leading case investigations, contact tracing, and outbreak investigations. Case investigation is the identification and investigation of individuals with confirmed and probable diagnoses of a reportable communicable disease, such as COVID-19. Contact tracing follows case investigation and is a process to identify, monitor, and support individuals who may have been exposed to a person with a communicable disease, such as COVID-19.

Health departments also administer communicable disease control measures within their jurisdictions to protect public health. This includes providing guidance to people with COVID-19 (cases) on isolation and people exposed to COVID-19 (contacts) on follow-up steps they need to take based on their vaccination status or history of prior infection in the past 90 days. Steps may include testing, wearing a mask, and quarantining.

If there are large numbers of cases reported to health departments, and the virus is easily and quickly spreading, health department resources can be overwhelmed. When requested by the health department, employer assistance may aid in limiting the spread of COVID-19 in the work environment.

Employer involvement

When health department personnel investigate a case of COVID-19, they will likely ask the person with COVID-19 questions about their work status and work environment, about people they have been in close contact with, and locations visited while they could have acquired or spread COVID-19 to others. If the health department learns a person is a confirmed or probable case of COVID-19 and was in a workplace where close contact with others (employees, customers, or community members) may have occurred, the health department may contact the employer, employees, or customers to let them know of potential exposures.

Confidential information about the infected individual, including their name and other personal identifying information, will not be revealed without their permission. Employers can assist the health department by:

• Providing further identification of potential people exposed to COVID-19 who worked in the same area and on the same shift,
• Hosting a site visit for health department personnel to observe the workplace and make workplace-specific recommendations to help prevent further spread of the virus, and
• Facilitating communication with employees.

The level of interaction between the health department and an employer will vary depending on several factors, such as the size and type of workplace, the number of people with COVID-19 associated with the workplace, the health department's capacity, and local, state, and federal laws and regulations.

In general, when a person with COVID-19 is identified, and the diagnosis impacts a workplace, the health department's level of involvement with the employer could include:

• Asking the employer for help in understanding the risk for transmission in the workplace and identifying people with COVID-19 and people exposed to COVID-19 in the workplace. This may include health department-initiated interviews, site visits, and record reviews to identify people exposed to COVID-19 and better understand risks for transmission within the workplace (e.g., barriers to physical distancing or use of well-fitting masks).
• Relying on the employer to identify people exposed to COVID-19 in theworkplace. While this is not typical, some health departments may make agreements with employers who have occupational health or medical programs or trained occupational safety and health staff to formally and confidentially carry out some aspects of contact tracing in the workplace. In such situations, to protect employees' privacy, health departments will take responsibility for case investigation and contact tracing outside of the workplace. If employers are interested in this type of agreement, they should contact their health department to discuss this option.
• Conducting workplace contact tracing without directly engaging the employer. The health department may not request assistance or information from the employer when the risk of further workplace transmission is low or the health department lacks the resources to follow up with the employer. They also may not be permitted to involve an employer because local or state privacy laws may limit third-party involvement in contact tracing without the person with COVID-19's consent.

Preparing to collaborate with the health department

How employers can assist with the COVID-19 response:

• Establish a COVID-19 coordinator or team. Employers may find it useful to identify a coordinator or team to oversee COVID-19 related activities. The COVID-19 coordinator/team should serve as a resource to the health department and the workplace as the primary point of contact for coordinating all COVID-19 activities. The COVID-19 coordinator/team should help to develop and put into action the hazard assessment activities discussed below.

  The COVID-19 coordinator/team can review CDC's Interim Guidance on Developing a COVID-19 Case Investigation & Contact Tracing Plan to better prepare and understand these processes. The COVID-19 coordinator/team can also visit the STLT health department website to see if specific local information for employers is available. Some jurisdictions may have state-based occupational health and safety surveillance programs that can assist.

  While the employer's COVID-19 coordinator/team can aid the health department when requested to carry out some contact tracing activities among their employees, they do not have the authorities to perform all aspects of these functions without consultation with the health department. For instance, employers can limit entry into the workplace by employees based on the employer's fitness-for-duty policies, but employers cannot ask about workers' activities or people exposed to COVID-19 outside of work.

• Create and implement a preparedness, response, and control plan. Employers can use guidance from the Occupational Safety and Health Administrationexternal icon to create a COVID-19 preparedness, response, and control plan. Making this plan will help employers evaluate the risk and decide on actions to prevent the spread of COVID-19 in the workplace. Having the plan will also allow employers to rapidly gather employee and workplace records, when needed, to assist possible health department-initiated case investigations and contact tracing. The employer may also decide to distribute this plan throughout their business.

• Collect information about the workplace. One of the most useful things an employer can do is to quickly prepare and provide information to the health department about the workplace, potential people exposed to COVID-19 in the workplace, and, when needed, workplace operations, without revealing confidential personnel records or business information. Examples of useful information to have on hand can be found on the page Investigating and responding to COVID-19 cases in non-healthcare work settings.

  • Note that all activities and information collected by an employer should be limited to the work setting and be consistent with applicable local, state, and federal privacy, health/medical, and workplace laws and regulations [e.g., U.S. Equal Employment Opportunity Commission (EEOC)external icon and Americans with Disabilities Act (ADA)external icon ].

    The Occupational Safety and Health Administration's (OSHA) guidance, Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplaceexternal icon , outlines employer requirements with respect to the recording of occupational illnesses, specifically people with COVID-19. Under OSHA's recordkeeping requirements, work-related COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19, if the person meets certain requirements. Employers are encouraged to frequently check OSHA's COVID-19 webpageexternal icon for updates.

• Support employees and conduct workplace hazard evaluation and prevention activities. Employers must provide a safe and healthy workplaceexternal icon , free from known hazards that are likely to cause death or serious physical harm. If an employee, customer, or a visitor in the workplace has symptoms consistent with COVID-19, self-reports a COVID-19 diagnosis, or has had close contact with someone with confirmed or probable COVID-19, an employer should quickly take action by conducting workplace hazard evaluation and prevention activities. These actions will help limit the spread of COVID-19 in the workplace.

  Employers should also consider carrying out a hazard assessmentexternal icon that can help identify potential hazards related to COVID-19. Employers should then use proper hierarchy of controls methods to limit the spread of COVID-19 in the workplace setting.

• Communicate with employees. Employers should inform employees that the health department will contact people diagnosed with COVID-19 or those who have had close contact with someone with COVID-19. Employers should encourage employees to work with the health department to discuss their illness, exposures, and people exposed to COVID-19 so the health department can limit further spread of COVID-19.

If employers are notified of a person with COVID-19 or person exposed to COVID-19, they must adhere to workplace and medical privacy laws and protections. Employers should also tell employees that when the health department notifies people who were exposed to COVID-19 in the workplace (close contacts), they will only share that they may have been exposed to COVID-19; they will not share names or any personal or medical information of the person infected with COVID-19 with close contacts. Based on the details of the exposure and vaccination status or history of prior infection in the past 90 days, the health department will offer recommendations for follow up, including getting tested, wearing a well-fitted mask, and quarantining if unvaccinated.

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