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Dear Colleagues,

Wisconsin is currently experiencing extremely high levels of community spread of the SARS-CoV-2 virus, leading to an unprecedented surge in COVID-19 disease and record numbers of hospitalizations and deaths. Aggressive multi-component, state-wide mitigation efforts are needed to reduce transmission to manageable levels. More than at any time before, ensuring strict isolation of people who are sick, and quarantine of individuals known to have been exposed, are necessary to disrupt chains of viral transmission and slow the epidemic.

Ensuring that people with COVID-19 stay home and out of close contact with others is a shared responsibility of health care providers, employers, health departments and all Wisconsin residents. Under Wisconsin law, Local and Tribal Health Departments have the authority to enforce isolation and quarantine under Chapter DHS 145. DHS has a toolkit of legal forms (see “Templates”) to assist LHDs with quarantine/isolation enforcement issues.


Guidance regarding return to work of healthcare personnel who have tested positive for COVID-19

For the purposes of this guidance, health care personnel (HCP) are defined following CDC criteria as any persons involved in direct patient care (e.g., nurses, nursing assistants, technicians, physicians, phlebotomists), as well as those not directly involved in patient care but who could be exposed (e.g., environmental services).  HCP are considered to include personnel working in hospitals, outpatient medical clinics, long-term care and assisted living residential facilities.

It is generally not appropriate for any person to attend in-person school or work if they have been diagnosed with COVID-19 and are within their infectious period. Outside of crisis situations in selected health care settings, return to work should only be allowed when a person has met the criteria for discontinuation of isolation, which for most people is 10 days after the onset of symptoms or the date of a first positive test. The CDC has provided guidance describing contingency and crisis standards of practice to mitigate healthcare personnel staffing shortages. The Wisconsin Division of Quality Assurance has also provided guidance describing a variance request process, by which Nursing Homes and Immediate Care Facilities may propose to use COVID-19 positive staff, after all other staffing options have been exhausted. 


Guidance regarding return to work of healthcare personnel following COVID-19 exposure

COVID-19 exposure is deemed to occur if HCP have prolonged close contact (i.e., within 6 feet for a total of 15 minutes or exposure of any duration during aerosol-generating procedures) with a patient, visitor, or co-worker while not wearing appropriate PPE. HCP may also have exposure after close contact with infected household members or persons in the community. Quarantine for 14 days is required for all individuals who have been exposed to COVID-19, unless they have recovered from a confirmed COVID-19 illness within the prior 90 days, or work in a health care or public safety setting that is experiencing a staffing crisis.

As described in HAN #16, DHS recognizes that situations may occur when excluding exposed healthcare personnel from work during their quarantine period could result in critical staffing shortages which threaten patient care and safety. To promote safer operations in these scenarios, DHS has partnered with stakeholders in health care and local public health departments to create guidance for returning to work after COVID-19 exposure.

Before allowing asymptomatic HCP who had unprotected COVID-19 exposure to return to work, healthcare facilities are encouraged to implement additional strategies to address staffing shortages, including:

• Shifting HCP to areas experiencing a staffing shortage
• Identifying additional temporary staff to work in the facility
• Postponing elective time off for critical HCP, as appropriate

If 14 day quarantine of HCP will adversely impact patient care, healthcare facilities should ensure the following protections are in place before allowing exposed HCP to return to work:

• HCP should be asymptomatic.
• HCP should report temperature and absence of symptoms before each shift.
• HCP should wear a facemask at all times for source control while in the facility. A higher level of personal protective equipment should be used when indicated.
• HCP, to the extent possible, should minimize contact with other persons outside of work and continue quarantining when at home.

To further minimize the risk of transmission from asymptomatic HCP who may become infectious during the 14 day incubation period, healthcare facilities should implement a serial testing strategy for all HCP who continue to work. Serial testing can be performed with either molecular (e.g., RT-PCR) or antigen tests. Facilities using antigen tests should understand their limitations, as described in HAN #17, and use molecular tests to confirm the results of positive antigen tests. A recommended serial testing and monitoring strategy is depicted below in Figure 1.

HCP who develop even mild symptoms at any time must stop working and return home. Any HCP who test positive for SARS-CoV-2 during serial testing, regardless of symptoms, must be excluded from work until they meet CDC criteria for return to work. If they were excluded from work because of a positive antigen test and remain symptomatic, they may return to work if a second test using a molecular assay is negative.

Healthcare facilities without access to testing with acceptable turnaround times (e.g. less than 48 hours) should exclude exposed HCP from work for the entire 14 day quarantine period. Facilities experiencing critical staffing shortages without adequate testing capacity should contact DHS for assistance procuring testing supplies and to discuss options for managing workforce shortages.

DHS encourages healthcare facilities to consider reviewing and revising paid leave, paid time off (PTO), and other policies to support HCP and encourage persons who are symptomatic to remain at home. Consider suspending no-fault attendance policies and let workers know that they won’t be terminated if they have to isolate. If the worker has exhausted paid sick time and PTO is not an option, consider offering unpaid time off.

DHS requests that health care organizations notify the local health department in all jurisdictions where HCP are being asked to work during the required quarantine period after a SARS-CoV-2 exposure. Figure 2 provides suggested language that may be submitted to local health departments by fax or email to provide this notification.  Staffing shortages should be re-evaluated regularly, to determine whether exceptions to home quarantine remain necessary for patient safety.