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Employment Practices

Balancing the roles of healthcare provider and employer can be a challenge. Get advice on how to write job descriptions, create applications, place help wanted ads, set meal breaks, establish alternative work schedules, and terminate an employee.

COVID-19 Employee Weekly COVID-19 Testing Tracking Form

August 11, 2021 14889


In accordance with the State Public Officer Order issued on July 26, employers must establish a method to track unvaccinated or incompletely vaccinated workers for weekly COVID-19 testing. 

  1. Unvaccinated or incompletely vaccinated* workers must also observe all other infection control requirements, including masking, and are not exempted from the testing requirement even if they have a medical contraindication to vaccination, because they are still potentially able to spread the illness. Previous history of COVID-19 from which the individual recovered more than 90 days earlier, or a previous positive antibody test for COVID-19, do not waive this requirement for testing.
  2. Diagnostic screening testing of asymptomatic fully vaccinated workers is not currently required. However, fully vaccinated workers may consider continuing routine diagnostic screening testing if they have underlying immunocompromising conditions (e.g., organ transplantation, cancer treatment), which might impact the level of protection provided by COVID-19 vaccine.
  3. Facilities with workers required to undergo workplace diagnostic screening testing should have a plan in place for tracking test results, conducting workplace contact tracing, and must report results to local public health departments. There are IT platforms available that can facilitate these processes for facilities.

*Definitions:  For purposes of this Order, the following definitions apply:

 A.  "Fully vaccinated" means individuals who are considered fully vaccinated for COVID-19: two weeks or more after they have received the second dose in a two-dose series (Pfizer-BioNTech or Moderna or vaccine authorized by the World Health Organization), or two weeks or more after they have received a single-dose vaccine (Johnson and Johnson [J&J]/Janssen). COVID-19 vaccines that are currently authorized for emergency use:

  1. By the US Food and Drug Administration, are listed at
  2. By the World Health Organization, are listed at

B.  "Incompletely vaccinated" means persons who have received at least one dose of COVID-19 vaccine but do not meet the definition of fully vaccinated.

Employers must verify and document an employee’s vaccine status. CDA Practice Support has resources available to help you with this.

Sample Employee COVID-19 Vaccination At-a-Glance Tracking Form 

Self-Certification of Employee Vaccination Status 

Employer responsibility for time and mileage:

Employers need to reimburse such common expenses as work-related travel and expenses incurred within the scope of employment. 

Employee expenses should be paid for costs associated with the COVID-19 test that are not otherwise covered by insurance, the time traveling to and from the testing site (in excess of the employee’s regular commute time) and time spent testing. 

The rate of pay for non-exempt (hourly) employees the time spent testing (non-productive work time) can be a paid at their regular rate of pay or reduced rate no lower than current state or local minimum wage. If employers should choose to establish a second reduced wage for weekly COVID-19 testing and travel time, employers should notify employees in advance (at least 15 days) of the new testing and travel wage rate. 

Employers who wish to implement a reduced wage for employee training and other non-productive time may use the Training and Non-productive Work Time Rate Sample Policy template to inform, document and collect employee acknowledgements for new practice policy. 

Use a Change in Relationship Form to document the reduced weekly COVID-19 testing and travel time rate and provide an updated Notice to Employee form.

Should a non-exempt (hourly) employee undergo weekly testing outside of work hours, employers should track and calculate for any applicable overtime and calculate for the highest rate paid or the Weighted Average Rate for any overtime incurred by the employee.

Exempt (salaried) employees should be reimbursed for any costs associated with mileage and testing. No additional wage compensation is required for exempt employees.

The 2021 IRS mileage rate is 56 cents for every mile of business travel driven.

For the most recent rate, visit the IRS website. The mileage rate is based on the study of vehicle operating cost that is conducted annually for the IRS.

COVID-19 Employee Testing Tracking Form
Minimum Wage and Paid Sick Leave Ordinances by City/County

Individual cities and counties across California have passed local ordinances relating to minimum wage and sick leave laws — with eligibility rules varying from city to city. Check with local city government as to whether any local minimum wage ordinances may apply to employees in your practice. Periodically check local websites as rates in these cities could change at any time.  

Interns and Volunteers

Employers should proceed with caution when using unpaid interns or volunteers. Most interns are considered employees in the eyes of the law, which means you must comply with wage and hour laws, including paying them at least minimum wage.

CFRA Guidance

Dental practice owners should be aware and prepared for major changes to California’s Family Rights Act that go into effect Jan. 1, 2021.

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End of Year Updates for Your Practice

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Employee Manual Resources

Create a personalized employee manual using an online tool or a sample employee manual.

General New Hire Toolkit

This toolkit covers recruiting, interviewing, hiring and onboarding, and provides a general list of basic hiring documents. If you are hiring a temporary employee or associate dentist, you will also need our additional hiring toolkits.

View General New Hire Toolkit
Hiring Associates Toolkit

Associates may be classified as either an independent contractor or an employee. This toolkit includes information to help you determine how to hire an associate.

View Hiring Associates Toolkit
Hiring Temporary Employees

Short-term employees are considered employees by the State of California and require additional documentation. This toolkit covers hiring, paying and terminating temporary employees.

View Hiring Temporary Employees Toolkit

View Hiring Temporary Employees Toolkit

Resource Library

Access an online library of downloadable articles, guides, templates, checklists and forms.

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