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643 Developing a COVID Prevention Program (CPP)
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Investigations

Personal identifying information of COVID-19 cases or symptoms will be kept confidential. COVID-19 testing or related medical services will be provided by the employer to ensure the confidentiality of employees. However, unredacted information on COVID-19 cases will be provided immediately upon request to the local, state, or federal agencies as required by law.

Investigation results and medical records are confidential.

All employee medical records will be kept confidential and not disclosed or reported without the employee’s express written consent to any person with the following exceptions:

  • Unredacted medical records provided to the local, state, and federal health agencies, or as otherwise required by law immediately upon request; and
  • Records that do not contain individually identifiable medical information or from which individually identifiable medical information has been removed.
Investigating COVID-19 Cases

All personal identifying information of COVID-19 cases or symptoms will be kept confidential. All COVID-19 testing or related medical services provided by us will be provided in a manner that ensures the confidentiality of employees, with the exception of unredacted information on COVID-19 cases that will be provided immediately upon request to [Reference local, state, and federal requirements.] or as otherwise required by law.

All employee medical records will also be kept confidential and not disclosed or reported without the employee’s express written consent to any person within or outside the workplace, with the following exceptions: (1) Unredacted medical records provided to [Reference local, state, and federal requirements.], or as otherwise required by law immediately upon request; and (2) Records that do not contain individually identifiable medical information or from which individually identifiable medical information has been removed.

Date: [enter date]

Name of person conducting the investigation: [enter name(s)]

Enter the following information in the inspection report:

  • Employee (or non-employee) name: [enter name]
  • Occupation (if non-employee, why they were in the workplace): [enter occupation]
  • Location where the employee worked (or non-employee was present in the workplace): [enter location]
  • Date investigation was initiated: [enter date]
  • Was the COVID-19 test offered? [enter yes/no]
  • Name(s) of staff involved in the investigation: [enter name(s)]
  • Date and time the COVID-19 case was last present in the workplace: [enter date/time]
  • Date of the positive or negative test and/or diagnosis: [enter date]
  • Date the case first had one or more COVID-19 symptoms: [enter date]
  • Information received regarding COVID-19 test results and onset of symptoms (attach documentation): [enter information]
  • Results of the evaluation of the COVID-19 case and all locations at the workplace that may have been visited by the COVID-19 case during the high-risk exposure period, and who may have been exposed (attach additional information): [enter information]
  • Notice is given (within one business day, in a way that does not reveal any personal identifying information of the COVID-19 case) of the potential COVID-19 exposure to:
    • All employees who may have had COVID-19 exposure and their authorized representatives. Names of employees identified and date: [enter names and dates]
    • Independent contractors and other employers present at the workplace during the high-risk exposure period. Names of employees identified and date: [enter names and dates]
  • Answer the following questions:
    • What were the workplace conditions that could have contributed to the risk of COVID-19 exposure? [enter answer]
    • What could be done to reduce exposure to COVID-19? [enter answer]

Knowledge Check Choose the best answer for the question.

3-2. Who may receive an employee's medical records without the express written consent of the employee?