Frequently Asked Questions around K-12 Testing Framework for 2022/23 School Year

Updates as of April 21, 2023:

Updated links and references to reflect changes in State Public Health Officer Orders and Cal/OSHA policy.
Focused on antigen testing as preferred modality.
Clarified and updated answers to questions about CDPH school testing programs.
Additional questions about test characteristics added and answered.

Table of Contents

K-12 School Testing Framework and COVID-19 School Guidance
State Supported Testing Options for the 2022/23 School Year
Over-the- Counter (OTC) and At-Home Antigen Tests
CDPH Professional and At-School Administered Antigen Tests

K–12 School Testing Framework and COVID-19 School Guidance

Are schools required to have a testing program?

Although schools are not required to maintain a testing program, CDPH strongly recommends that schools facilitate access to testing, particularly for vulnerable populations within their communities. Testing, especially of individuals presenting COVID-19 symptoms and those exposed to a positive COVID-19 case, remains an important step for minimizing transmission and keeping students in the classroom for in-person instruction. 

Is the State Public Health Officer Order "Vaccine Verification for Workers in Schools (August 11th, 2021)" still in effect?

No. On September 17, 2022 the State Public Health Officer Order (August 11, 2021) concerning Vaccine Verification for Workers in Schools was rescinded.

What are the requirements for workplace or employee testing in K–12 Schools for 2022/23?

In the workplace, employers are subject to the Cal/OSHA COVID-19 Prevention Non-Emergency Regulations or in some workplaces the Cal/OSHA Aerosol Transmissible Diseases (ATD) Standard (PDF), and should consult those regulations for additional applicable requirements.

For questions on implementation, contact Cal/OSHA directly.

What should we do with leftover or expired testing supplies?

Reach out to your local County Office of Education (COE) and your local health department (LHD) to determine if there is a need elsewhere for your tests. If not needed elsewhere, reach out to schooltesting@cdph.ca.gov for disposal information.  

For over-the-counter (OTC)/at-home tests

Note that many OTC/at-home test brands have had formal extensions by the FDA and are valid for many months after the date printed on the box. For more information, visit the FDA OTC COVID-19 Diagnostics Tests page.

OTC/at-home tests can be disposed of in the regular trash.

What if my OTC tests are older than the extended expiration date found on the FDA website?

Although CDPH recommends replacing tests that have expired with new tests, if no new tests are readily available, you may use your expired test aas long as the internal control remains valid. 

For professional antigen tests

Expiration dates for the Clinical Laboratory Improvement Amendments of 1988 (CLIA)-waived professional antigen tests have been extended. Do NOT dispose of tests based on the date printed on the boxes. Your site will be specifically contacted by CDPH with instructions if specific lot numbers are used beyond their extended expiration dates. Unwanted, unexpired professional tests cannot be returned to CDPH for reuse due to federal regulations. We cannot help directly facilitate transfer of tests due to regulatory reasons. Your local COE or health department may provide local guidance for excess unexpired tests. Before contacting CDPH, be sure there are no other ways your school might use these tests through the end of the school year. If tests are truly not needed elsewhere, reach out to schooltesting@cdph.ca.gov for disposal instructions.

For PCR/Molecular Tests

Read our flyer on how to dispose of PCR/Molecular testing supplies.

Wet swab PCR tests (tubes with liquid in them) must be disposed of at a local hazardous waste facility. Dry swab PCR tests can be disposed of in regular trash. CDPH is assisting schools in properly disposing of PCR tubes with liquid in them. For more information, see the PCR Disposal Flyer or email schooltesting@cdph.ca.gov. 

State Supported Testing Options for the 2022/23 School Year

What type of testing support is being offered by the Testing Task Force for the 2022/23 School Year? 

At-Home Testing (tests sent home for students and parents to test/report before coming to school or when symptomatic)

CDPH expects that most testing in school communities can be performed with at-home antigen testing that are provided by CDPH at no cost to schools.

Professional/In-School Antigen Testing for in-school testing (tests overseen and performed on-site by school staff)

At-home tests may not meet all school-related testing needs, particularly in communities with limited English proficiency and/or lower health or technology literacy. Schools with a need for in-school testing may consider the CDPH K–12 Professional antigen program.
Complete the Application for K-12 School Antigen Programs

Over-the-Counter (OTC) and At-Home Antigen Tests

Why is the Testing Task Force encouraging schools to use At-Home Antigen Testing as the primary option for the 2022/23 School Year? Why are we moving away from PCR testing?

Lab-based molecular testing (PCR/LAMP) has several disadvantages in the school setting. It is sensitive enough that it picks up very low levels of virus, both before and after an infection (sometimes for months). Detecting low levels of virus in a person who is not able to transmit can make them unnecessarily miss school, despite feeling well and not being a risk to others. Also, because lab-based molecular tests (PCR/LAMP) need to go to a lab, results are much slower. The time from nose swab to result is often 2–3 days (including ti me at collecting site, time in transport, and time in lab processing). For someone who has virus levels that are high enough to transmit virus, an antigen test that gives rapid results is much better to guide immediate isolation to prevent transmission. Antigen tests may not catch every early or late case, but they are good at detecting high levels of virus, when it is important to isolate immediately.

What are the differences between professional antigen testing versus at-home testing?

OTC/at-home and professional antigen tests are similar in terms of performance. If you are planning to conduct testing on others, you must participate in a professional antigen testing program. Professional antigen tests can be used at-school on students. 

OTC/at-home tests are meant to be used as self-tests by individuals or parents/guardians. If they are used outside the home, they must still be completed (both conducting and interpreting the test) by individuals or parents/guardians. Users should follow the age parameters for self-administration associated with the particular OTC/at-home test they are using (typically 14 years or older). For those younger than the minimum age, guardians can administer and perform the test for children.

Professional antigen testing must be used if staff performs tests on others. Your organization needs to apply to use professional tests under CDPH's School CLIA Waiver if your organization serves K–12 students. CDPH's School CLIA only covers Abbot BinaxNow professional antigen tests and no other brands of antigen tests. Staff should not administer OTC/at-home tests on other people, but may allow children (if old enough by specific test recommendations) or parents/guardians to conduct the test and read results themselves. Staff may provide educational resources for families to conduct the tests themselves. Using OTC/at-home tests can free up staff time and to move testing operations to parents and students in the 2022/23 school year. Access free educational materials to distribute to students/parents and staff. 

Can school staff provide an OTC/at-home kit to a student to self-administer on campus?

Yes, school staff can provide a student or staff that meets OTC/at-home age requirements to self-administer the OTC/at-home test on campus. Users should follow the age parameters (typically 14 years or older to be able to self-administer the test) associated with the particular brand of OTC/at-home test they are using. OTC/at-home tests are self-tests to be completed (both swabbing and performing the test) by individuals or parents/guardians regardless of where they test (in their home or elsewhere) and should not be used by staff to test others.

Will OTC/at-home tests continue to be provided by the state?

Yes. We plan to continue to provide OTC/at-home tests through the 2022-23 academic year.

Can expired OTC/at-home tests be used beyond their expiration date?

CDPH endorses the emergency use of OTC/at-home COVID-19 Tests beyond their FDA-authorized expiration (PDF) as long as the internal control remains valid.

When can OTC/at-home tests be used?

At-home tests can be used in any of the same scenarios that professional/at-school antigen tests are used. Some examples of use of antigen tests include:

Testing of symptomatic individuals.
Outbreak response testing
Testing of school members for end-of-year events such as graduations 
Testing of individuals exposed to someone diagnosed with COVID- 19.
Testing as recommended by CDPH Guidance on Isolation and Quarantine

Do we need to have a CLIA waiver to submit an order for the at-home antigen tests?

No. CLIA waiver is needed to order OTC/at-home tests, as these are self-tests to be performed by the individual or their parent/guardian.

Do sites need to obtain CLIA waivers if they are providing students with OTC/at-home tests but not administering the test?

No. However, schools may enroll in the CDPH Professional/at-school Antigen Testing program if they wish to have the option of administering BinaxNOW professional tests on site if needed.  Complete the Application for K-12 School Antigen Testing Program.

Can schools track the OTC/at-home test results?

Yes, schools enrolled in Primary.Health can track self-reported student results. If your school/LEA is interested in enrolling in Primary.Health to track results, please email CArapidtest@primary.health and indicate you need a school account for OTC/at-home only.  They will walk you through the steps of generating a registration link to share with your school community.

If your school opts not to create your own individualized profile on Primary.Health, please encourage self-reporting:

How can students report their OTC/at-home test results?

We strongly encourage individuals to report their results from their OTC/at-home test on Primary.Health, which is an online platform that allows individuals to securely consent to testing and self-report their results (including photos of test results). Schools can share their unique registration link with students that allow the school to see the students' results, or share the generic reporting link.

Can parents upload any brand of OTC/at-home test result to Primary.Health?

Yes, they can report specifically any brand of OTC/at-home tests.

Who can report OTC/at-home tests on Primary.Health?

Students, staff, and school community members can use Primary.Health to report OTC/at-home tests results. Schools/districts can request a Primary.Health account or use a preexisting account to track results.

Will OTC/at-home test distribution be contingent upon using Primary.Health?

No. Reporting in Primary.Health is recommended but not required.

Some of our staff and families who have used OTC/at-home antigen tests have tested negative initially and then tested positive on day 4 or 5. Can we trust OTC/at-home results?

This has been reported with both professional and OTC/at-home antigen test results. Antigen tests are about 60% sensitive when compared with PCR tests. However, for persons with enough virus to be likely infectious, antigen test sensitivity increases into the 90% range. What this means is that antigen tests are very good at letting someone know if they can infect others and results are available in 15 minutes. For best results in symptomatic patients, we recommend repeating a negative antigen testing with at least 24–48 hours between tests. Studies have shown that home-administered antigen tests have similar sensitivity to professionally administered antigen tests.

How does CDPH measure spread of COVID-19 if OTC/at-home tests are not included in case counts?

The state considers multiple data points to determine the community transmission levels including wastewater surveillance, case counts, probable case count (antigen tests), and hospitalization data.

CDPH Professional and At-School Administered Antigen Tests

How do I onboard my school into the CDPH/Primary.Health professional (at-school) antigen program?

Please complete the Application for K-12 School Antigen Program. After filling out the form, you will be sent an email with further instructions and a link to our Memorandum of Understanding (MOU) to sign.

Can we continue to order professional Binax Now kits once we are enrolled in the professional/at-school antigen program, even if we are participating in the OTC/at-home program?

Yes, you can participate in both the OTC/at-home and the professional antigen programs.

Will professional antigen tests continue to be provided to schools through the 2022-23 academic year?

Yes. We plan to continue to provide at-home and CLIA-waived professional antigen tests through the 2022-23 academic year.

We are starting our 2023 summer programming soon. Will we be able to continue to use the unused, professional rapid antigen tests during the summer?

Yes, you can use the unused, on-site rapid antigen tests during your summer program on campus through June 30, 2023, as long as you are still reporting in Primary.Health and have signed the 2022–2023 MOU. CLIA-waived onsite professional antigen testing after that date is not yet determined.

For schools already participating in the CDPH Professional Antigen Testing program: how do we get newly hired staff trained and set up with Primary.Health?

To set up a new Primary.Health account, the site administrator can create new team members in Primary.Health or can email CArapidtest@primary.health.

New testers can review training requirements and sign up for CDPH hands-on training at Next Steps for Starting Your CLIA-waived COVID-19 Antigen Testing Program.

Does the CLIA Waiver have to be renewed yearly?

Yes, we will require that a new MOU to be signed yearly to continue using CLIA waiver.

How do we order more professional (at-school) BinaxNOW antigen tests?

Use this link to place an order for professional antigen tests. Note you need to be onboarding, or have already completed, enrollment in the antigen program to order professional kits.

Will CLIA certification allow testing of children younger than 4 years and 9 months of age or unable to self-swab for other reasons?

People ages 4 years and 9 months and older and able to self-swab can participate in professional testing. There are no healthcare personnel requirements to supervise self-swabbing and our general consent covers tests completed by self-swabbing. 

CDPH Professional School Antigen Program allows for testing people unable to self-swab only if a qualified healthcare provider conducts assisted-swabbing.

OTC/at-home tests can be performed by parents/guardians on their own child (age limit depends on brand), but should not be performed on children by staff. Our program operates with supervised self-swabbing.

Age Guidelines

Test	Age	Who can swab
Professional antigen testing with school staff	Older than 4 years 9 months	Participants must self-swab while under observation
Professional antigen testing with a qualified healthcare professional in PPE (FIT-tested N95, etc.)	Older than 2 years	Qualified healthcare provider swabs (assisted swabbing) individuals unable to self-swab or those ages 2 years to 4 years 9 months with an additional consent needed
At-home testing with the OTC/at-home tests	Older than 2 years on average (depends on brand, please check IFU)	Guardians swab children or participants self-swab and then guardian performs and interprets OTC test

If your school would like to offier assisted swabbing at school to participants who are too young or cannot self-swab, please note that:

1. Swabbing must be done by a certified healthcare provider who is in proper PPE (N95 that has been FIT tested, etc.)

2. Primary.Health allows staff and students to provide consent, provides test results in a HIPAA-compliant way, and transmits results to local and state health departments. Please email carapidtest@primary.health with the subject line "Self-Swab Consent" to obtain a student's record of consent.

Please refer to the School Antigen Professional Testing Program playbook for more information.

Is my district/school authorized to test under the state CLIA waiver?

If you are unsure if your school/district has completed the CDPH onboarding process to test under the state CLIA waiver, please email schoolbinax@cdph.ca.gov to find out.

Our program’s testing staff are changing. How do we help transition?

Make sure new employees are receiving communications by having them join our listserv. 
Please email Primary.Health and ensure that your new leadership has an account with correct access at CArapidtest@primary.health. 
Please ensure they have completed our CDPH Hands-On Antigen Training. 
Please email schoolbinax@cpdh.ca.gov informing our program of the name of your organization and who is leaving and the new person and their contact information (email and phone number) so we can update our records.

Can one individual test positive while other household members with the same or similar symptoms continue to test negative with either PCR or rapid antigen tests?

Yes, people with different immune systems can have different symptoms for a specific level of detectable virus -- many symptoms are likely the "primed" immune system (from prior exposure or prior vaccination) responding quickly to virus that is not detected by the tests. More information cane be found in this New York Times article and the CDPH Testing Guidance page.

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Frequently Asked Questions around K-12 Testing Framework for 2022/23 School Year

Are schools req​uired to have a testing program?

Is the State Public Health Officer Order "Vaccine Verification for Workers in Schools (August 11th, 2021)" still in effect?

What are the requirements for workplace or employee testing in K–12 Schools for 2022/23? ​

What shoul​d we do with leftover or expired testing supplies?

For over-the-counter (OTC)/at-home tests

What if my OTC tests are older than the extended expiration date found on the FDA website?

For professio​nal antigen tests

For PCR/Molecular Tests

What type of testing support is being offered by the Testing Task Force for the 2022/23 School Year?

Over-the-Counter (OTC) and At-Home Antigen Tests

Why is the Testing Task Force encouraging schools to use At-Home Antigen Testing as the primary option for the 2022/23 School Year? Why are we moving away from PCR testing?

What are the differences between professional antigen testing versus at-home testing? ​

Can school staff provide an OTC/at-home kit to a student to self-ad​minister on campus?

Will OT​C/at-home tests continue to be provided by the state?

Can expired​ OTC/at-home tests be used beyond their expiration date?

When can OTC/at-home tests be ​used?

Do we need to have a CLIA waiver to submit an order for the at-home antigen tests?

Do sites need to obtain CLIA waivers if they are providing students with OTC/at-home tests but not administering the test?

Can schools track the OT​​C/at-home test results?

H​ow can students report their OTC/at-home test results?

Can parents upload​ any brand of OTC/at-home test result to Primary.Health?

Who can re​port OTC/at-home tests on Primary.Health?

Will ​OTC/at-home test distribution be contingent upon using Primary.Health?

Some of our staff and families who have used OTC/at-home antig​en tests have tested negative initially and then tested positive on day 4 or 5. Can we trust OTC/at-home results?

How d​oes CDPH measure spread of COVID-19 if OTC/at-home tests are not included in case counts?

How do I onboard my school into​ the CDPH/Primary.Health professional (at-school) antigen program?

Can we continue to order professional Binax Now kits once we​ are enrolled in the professional/at-school antigen program, even if we are participating in the OTC/at-home program?

Will professional antigen tests continue to be provided to schools through the 2022-23 academic year?

Are schools required to have a testing program?

What are the requirements for workplace or employee testing in K–12 Schools for 2022/23?

What should we do with leftover or expired testing supplies?

For professional antigen tests

What type of testing support is being offered by the Testing Task Force for the 2022/23 School Year? 

Why is the Testing Task Force encouraging schools to use At-Home Antigen Testing as the primary option for the 2022/23 School Year? Why are we moving away from PCR testing?

What are the differences between professional antigen testing versus at-home testing?

Can school staff provide an OTC/at-home kit to a student to self-administer on campus?

Will OTC/at-home tests continue to be provided by the state?

Can expired OTC/at-home tests be used beyond their expiration date?

When can OTC/at-home tests be used?

Can schools track the OTC/at-home test results?

How can students report their OTC/at-home test results?

Can parents upload any brand of OTC/at-home test result to Primary.Health?

Who can report OTC/at-home tests on Primary.Health?

Will OTC/at-home test distribution be contingent upon using Primary.Health?

Some of our staff and families who have used OTC/at-home antigen tests have tested negative initially and then tested positive on day 4 or 5. Can we trust OTC/at-home results?

How does CDPH measure spread of COVID-19 if OTC/at-home tests are not included in case counts?

How do I onboard my school into the CDPH/Primary.Health professional (at-school) antigen program?

Can we continue to order professional Binax Now kits once we are enrolled in the professional/at-school antigen program, even if we are participating in the OTC/at-home program?