Keenan Briefings


COVID-19 Surveillance Testing Information for Essential Workers

December 11, 2020

With the increased requirement to offer COVID-19 testing to employees, we have compiled COVID-19 surveillance testing information from some carriers and laboratories to assist our clients. You are encouraged to check with your local county department of public health for other surveillance testing options that may be offered at no cost.

With the recently passed emergency Cal/OSHA regulations and the requirement to provide COVID-19 testing for employees who are not essential workers, employers may encounter problems identifying and obtaining testing resources. Keenan will release a separate briefing specifically detailing the new Cal/OSHA emergency regulations.

The information included in this briefing on COVID-19 testing is accurate at the time of publication, December 11, 2020. Because testing issues may change, we have included carrier and laboratory website links in this briefing. We encouraged you to check directly with the carriers and laboratories for the most up-to-date information. Details on surveillance testing through medical pools/JPAs are not included, as each of these groups are setting their own requirements.


Keeping employees safe and healthy from coronavirus (COVID-19) continues to be of utmost concern. While Anthem Blue Cross benefits have included testing for COVID-19, the California Department of Managed Health Care (DMHC) has issued regulations regarding COVID-19 diagnostic testing for essential workers. Effective July 17, 2020, the requirements for essential workers apply to fully insured businesses regulated by the DMHC.

The following information explains the pertinent details needed to help employees understand their COVID-19 testing benefits with Anthem Blue Cross. This information is based on current federal and state requirements and is subject to change as federal and state instructions evolve.

Additional information can be found on Anthem's website; click here. Contact your Keenan representative for a copy of Anthem's current flyer on file regarding this information.

Blue Shield

Blue Shield is providing COVID-19 testing for essential workers as defined by the DMHC Emergency Testing Regulation. Blue Shield has provided a flow chart for establishing whether you meet the essential worker's definition and how you should handle testing.

Additional information can be found on Blue Shield's website; click here. Contact your Keenan representative for a copy of Blue Shield's essential worker flowchart.

Kaiser Permanente – Northern and Southern California

Kaiser recommends getting a diagnostic test if you currently have symptoms of COVID-19. If the test shows you are infected, you should isolate to help prevent spread. Testing also supports public health agencies' efforts to monitor the spread of the disease.

There is still a limited supply of tests throughout the country. Kaiser currently has more requests than tests, so they are prioritizing high-risk patients first, so they can self-isolate and help keep the virus from spreading. Kaiser is currently specifically prioritizing asymptomatic teachers and school staff who are deemed essential workers. They are rapidly expanding testing capacity by procurement of additional equipment and supplies and will communicate when further testing is available at Kaiser Permanente facilities.

Flyers for both northern and southern California Kaiser clients are available from your Keenan representative. Additional information on Kaiser's testing can be found on their website; click here.

Getting testing outside of Kaiser Permanente

To receive a diagnostic test of COVID-19, asymptomatic teachers, and school staff should go to an external licensed independent facility (e.g., CVS, Walgreens, Walmart, or other retail locations or private lab). Many of these facilities bill Kaiser Permanente directly; co-members may not have to pay anything out of pocket. If charged, members should to and follow the flyer's steps (a copy of the flyer is available from your Keenan representative).

Sutter Health

As defined by the Department of Managed Health Care's (DMHCs) Emergency Regulations issued July 17, 2020, for essential workers who are without symptoms and known exposure, Sutter Health Plus covers the cost of the COVID-19 diagnostic test for its members. The standard non-preventive laboratory services cost-share applies. Cost-share is the amount members must pay when they receive covered services. A member's cost-share is based on the plan a member selects and can be a copayment, coinsurance, or deductible. We encourage members to review the Benefits and Coverage Matrix for their plan to get detailed information on their cost-sharing requirements.

CUUR Diagnostics is an out-of-network provider. Sutter Health Plus will cover COVID-19 testing services done by out-of-network providers if members cannot get COVID-19 testing services in-network within the established timeframes (as required by the DMHC's Emergency Regulations issued July 17, 2020). Out-of-network providers must send eligible claims to the address on the Sutter Health Plus member's identification card. Sutter Health Plus extends coverage of COVID-19 testing only to payment of the claim line item for testing. We do not cover convenience fees, taxes, mailing charges, shipping charges, or physician oversight fees.

Sutter Health Plus will consider claims and encounter expenses for the current plan year (including COVID-19 testing experience) when calculating renewal rates by the rating methodologies filed with the DMHC.

Additional information is available on Sutter Health's website; click here.

United Healthcare

If a member has been exposed or has symptoms, COVID-19 testing will be cover as mandated by the Federal CARES Act. The PCP will refer the member to an approved testing location. For asymptomatic essential workers, we follow DMHC guidelines; members will need to contact UHC customer services and mention they are essential workers.

UHC does not approve Third Party COVID testing.

Additional information is available on United Healthcare's website; click here.

Laboratory Testing Information

In the event you decide that you do not want to run all of the COVID-19 surveillance testing for essential workers through your health care plan, and your local county does not have enough tests to provide surveillance testing, a list of laboratories and their capacities are can be provided by your Keenan account representative.

Should you have questions, please contact your Keenan representative.

Keenan & Associates is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Clients are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the clients’ business activities.