December 6, 2023

The California Department of Public Health on Sept. 17 ended the COVID-19 testing mandate for unvaccinated health care workers and other individuals in high-risk settings, which include dental offices.

Unvaccinated dentists and their staff have been complying with the state’s public health order requiring vaccination or weekly testing since full compliance began Aug. 23, 2021. Dental staff who did not provide proof of COVID-19 vaccination were required to test weekly and submit proof of a negative test to their employer.

Dentist employers had tracking and documentation obligations as part of the state mandate. CDA members used resources during this time to assist their compliance, including CDA’s self-certification of employee vaccination status, a weekly testing tracking form for employees and forms for requesting and documenting vaccination exemptions. 

Other high-risk health care settings that are no longer subject to the weekly or twice-weekly testing requirement include, but are not limited to, doctor offices, general acute care hospitals, skilled nursing facilities, acute psychiatric facilities and homeless shelters. 

Although the state order has been lifted, some cities and counties continue to mandate weekly COVID-19 testing. Employers must follow the stricter order, whether federal, state or local, and should check with their local health department to ensure compliance.

Vaccine coverage ‘high among workers in high-risk settings’

The state’s news release announcing termination of the July 21 2021, public health order notes the high rate of vaccination among workers in high-risk settings. CDA’s own survey conducted in May-June 2021 showed 94% of California dentists had been vaccinated against COVID-19.

The different behavior of the omicron subvariants — chiefly, their increased transmissibility even among vaccinated, boosted and previously infected individuals — also influenced CDPH’s decision to rescind the vaccinate-or-test mandate.

“Mandated testing of the small number of unvaccinated workers is not effectively preventing disease transmission as with the original COVID-19 virus and prior variants earlier in the pandemic,” CDPH stated. “Consequently, while COVID-19 remains with us, I am rescinding the July 26, 2021 State Public Health Officer Order effective September 17, 2022,” the state public health officer wrote. 

Employers encouraged to continue promoting vaccination, testing 

While weekly testing requirements are ending, CDPH encourages employers to continue providing testing resources to staff to slow the spread of COVID-19 in communities, observing that “vaccination and testing are two key measures that help mitigate the spread of COVID-19, as is masking and improving indoor ventilation.”

Dentists can continue to use resources in CDA’s Vaccine Confidence Toolkit to administer rapid tests in their practice, manage employees and discuss vaccine safety and efficacy with their patients. Just last week, with the assistance of a CDPH grant, CDA published new infographics, vaccination talking points, sample social media posts and other resources for use specifically in dental offices.

Additionally, dentists and other employers in California can still choose to mandate that their workers be vaccinated against COVID-19. Member dentists can use CDA’s sample vaccination policy, which includes instructions and considerations for employers, including circumstances when employees may be exempt from complying.

Masking, screening, reporting requirements continue in dental offices

Dentists and their staff, as well as patients and visitors in dental offices and other health care settings in California, must continue to wear face masks, and employers must provide properly fitted respirators to staff involved with aerosol-generating procedures. Cal/OSHA requires use of respirators during such procedures in both dental and medical settings.

Dental offices also must continue to screen patients for COVID-19 as required by Cal/OSHA. 

CDA has FAQ on masking and screening requirements and an article with detailed information about continuing reporting and return-to-work requirements per the current Cal/OSHA COVID-19 Emergency Temporary Standards that end Dec. 31.  

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