TB and health screening for hospice staff, by the rule that applies
No federal hospice rule requires TB testing for staff. CDC recommends a baseline screening, and several states add TB and health screening rules of their own. Personnel Ledger tracks the ones that apply to you, with the date and the result in each person's file.
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Built from CDC guidance for health care personnel, accreditor checklists and state law in ten states. General information, not legal advice. Confirm your specifics with your state and your accreditor.
No federal hospice rule, a CDC baseline, and your state
The federal hospice Conditions of Participation contain no TB testing requirement for staff. TB rules come from your state, your accreditor or your own policy.
Not in 42 CFR Part 418CDC recommends baseline screening for health care personnel: an individual TB risk assessment, a TB symptom evaluation, a TB test, and further evaluation as needed.
CDC, MMWR 2019;68:439-443CDC says annual TB testing of health care personnel is not recommended unless there is a known exposure or ongoing transmission at a health care facility.
CDC, MMWR 2019;68:439-443Accreditors can add more. ACHC's annual compliance checklist expects annual TB risk assessments that decide the type and frequency of screening for direct care personnel. That is an accreditor standard, not a federal rule.
Yearly TB education is a different thing from a yearly test. CDC recommends annual TB education for health care personnel, which you can log alongside your orientation and training records.
TB and health screening rules in ten states
Several states set their own rules for hospice staff. This is what we found in the ten states with the most hospices.
| State | TB | Health screening |
|---|---|---|
| California | TB screening around hire and every year for physician, nursing and aide staff under the state licensing standards; Cal/OSHA also requires a TB assessment at least yearly for exposed employees. | A health exam from 6 months before to 14 days after hire for physician, nursing and aide staff. |
| New York | Before hire: a TB risk assessment, a symptom check and a TB test. Then a yearly assessment, with tests only as indicated. | A health assessment before patient contact and every year, plus measles and rubella immunity and a flu vaccine or a mask in flu season. |
| Arizona | Proof of freedom from infectious TB on or before the start date for staff with direct patient interaction, then a yearly symptom-free statement signed by a medical practitioner, not a yearly test. | We did not find one beyond TB. |
| Illinois | A TB test with the initial health evaluation. Baseline only, following CDC 2019. | An initial health evaluation within 30 days before or after hire. |
| Michigan | Screening at hire on the CDC baseline approach. | Immunization status checked at hire. |
| Ohio | A written communicable-disease and TB screening policy for staff and volunteers with direct contact. No interval is set. | Covered by the same written policy. |
| Georgia | No TB test interval set; infection-control policies cover TB surveillance. | An initial and yearly health screening by a licensed professional for staff and volunteers with patient or family contact, and for the administrator. |
| Texas, Florida and Pennsylvania | We did not find one. | We did not find one. |
For background checks, aide credentials and the rest of each state's rules, see hospice staff requirements by state.
The screening your rule asks for, and nothing more
Baseline, once
Track a baseline screening as a one-time item, due a set number of days from hire, with the date and the result.
Yearly where a rule says so
Where your state or your own risk assessment calls for it, make it repeat every 12 months and it comes due again on its own.
Only the roles it covers
Apply it to the roles your rule names. Everyone else shows as exempt, with the reason, instead of as missing.
Status and dates first
Record the status and the dates. Attaching the result is optional, so the file can hold the proof without holding more health detail than it needs.
Reminded in time
Staff get an email before a yearly screening comes due, and managers see it in their weekly digest.
TB and health screening, answered
Does Medicare require TB tests for hospice staff?
No. The federal hospice Conditions of Participation (42 CFR Part 418) contain no TB testing requirement for staff. Requirements come from state law, accreditors and agency policy.
What does a baseline TB screening include?
CDC recommends an individual TB risk assessment, a TB symptom evaluation, a TB test, and further evaluation for TB disease as needed (Sosa et al., MMWR 2019;68:439-443).
What does CDC say about yearly TB tests?
CDC says annual TB testing of health care personnel is not recommended unless there is a known exposure or ongoing transmission at a health care facility. Some states still set a yearly assessment or statement, and ACHC expects an annual TB risk assessment for direct care staff.
Which states require health screening for hospice staff?
Of the ten states we researched: Georgia, an initial and yearly health screening for staff and volunteers with patient or family contact; New York, before patient contact and yearly; Illinois, an initial health evaluation within 30 days of hire; and California, a health exam around hire for physician, nursing and aide staff.
Is staff health information protected health information?
Not under HIPAA when you hold it as an employer: HIPAA excludes employment records held by a covered entity in its role as employer (45 CFR 160.103). It is still sensitive, and OSHA treats some of it as a confidential employee medical record, so keep the file to status and dates and limit who sees any document.
Can we track flu shots and immunizations too?
Yes. Add each one as its own requirement, with a 12-month repeat for flu. No federal hospice rule requires them; New York, for example, requires measles and rubella immunity and a flu vaccine or a mask during flu season.
This page is general information, not legal advice. TB and health screening rules come from your state, your accreditor and your own policy, and they change. Confirm your state's current rule with your state licensing authority.
Keep every screening date where a surveyor can find it
Personnel Ledger tracks the TB and health screening your state and your policy require, with status and dates in each person's file. Start a free 45-day trial and set up your first requirement today.