Based on the information provided to Residential Care Services this week by LeadingAge WA, RCS will very likely be:

• Filing emergency rules to temporarily suspend TB requirements in NH that interfere with the COVID vaccine process (such as timeframes for when a TB test must be done);
• Immediately (this week) send out a Dear Administrator letter informing providers of the CDC guidance and our intent to file emergency rules.  Also inform providers they may suspend TB testing now for any staff or residents who will be receiving the COVID vaccine (either the 1^st or 2^nd dose);
• Start permanent rule making process to address how TB testing will be conducted in the future as the COVID vaccine becomes routine and may need to be given on a regular basis (i.e. yearly like the influenza vaccine).  This permanent rulemaking may need to be done in more than one program to assure TB testing and COVID vaccines don’t interfere with each other in the future (currently it is not an issue in the other programs because the rules are suspended in those programs).

LeadingAge WA has asked that the rules be suspended retroactively for those residents or staff who have already received the first vaccine dose and will miss the TB test required within 3 days of hire or admission as well as those who will not be able to submit to TB testing for 4 weeks following the second COVID vaccine dose.

Please make sure you have a plan for timing of the vaccine with your TB tests for residents and staff. The TB testing waiver is still in effect for Assisted Living facilities.

CDC clinical guidance on TB testing available through this link: https://www.cdc.gov/vaccines/covid-19/info-by-product/clinical-considerations.html.   The CDC guidance is the organization should develop a plan based on timing for vaccines and the testing.

Inactive vaccines do not interfere with tuberculosis (TB) test results. There is no immunologic reason to believe either a Tuberculin Skin Test (TST) (administered by intradermal placement of 0.1 cc of purified protein derivative) or blood draw for interferon gamma release assay (IGRA) would affect the safety or effectiveness of mRNA COVID-19 vaccines. We have no data to inform the impact of the COVID-19 mRNA vaccines on either TB test for infection (i.e., TST or IGRA).

For healthcare personnel or patients who require baseline TB testing (at onboarding or entry into facilities) at the same time they are to receive an mRNA COVID-19 vaccine:

• Perform TB symptom screening on all healthcare personnel or patients.
• If utilizing the IGRA, draw blood for interferon gamma release assay prior to COVID-19 vaccination.
• If utilizing the TST, place prior to COVID-19 vaccination.
• If vaccination has been given and testing needs to be performed, defer TST or IGRA until 4 weeks after COVID-19 vaccine 2-dose completion.
  • All potential recipients of COVID-19 vaccination should weigh the risks and benefits of delaying TST/IGRA with their providers.

 For healthcare personnel who require testing for other reasons:

• Perform TB symptom screening on all healthcare personnel
• Test for infection should be done before or at the same time as the administration of COVID-19 vaccination. If this is not possible, prioritization of test for TB infection needs to be weighed with the importance of receiving COVID-19 vaccination based on potential COVID-19 exposures and TB risk factors.
  • Healthcare personnel with high-risk conditions for TB progression should be fully evaluated as soon as possible.
  • Healthcare personnel without high-risk conditions for TB progression should proceed with contact tracing (i.e., symptom screening, chest radiograph or other imaging, specimen for microbiologic evaluation) but delay test for TB infection (TST or IGRA) if prioritized for receiving COVID-19 vaccination.
  • All potential recipients of COVID-19 vaccination should weigh the risks and benefits of delaying TST/IGRA with their providers.

This has been confirmed with Dept of Health and CDC.

It appears that ACIP is recommending that TB testing be deferred for 4 weeks after COVID vaccine 2 dose completion for healthcare personnel or patients who require baseline TB testing (at onboarding or entry into facilities) AND have already started COVID-19 vaccination.

For healthcare personnel who require annual testing or for other reasons, the TB test should be done before or at the same time as the administration of COVID-19 vaccination.

Questions?

Contact:

Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services
c: 425-231-4804