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1. Why is this change in testing strategy occurring?

In 2020, the Governor announced the first phase of a Unified Testing Strategy to significantly expand and better coordinate COVID-19 testing across the state. This was due to the critical need for testing and the lack of public health capacity (both at the CDC & at KDHE).  

The Unified Testing Strategy asked commercial and university labs to help the State double the amount of testing in Kansas by the end of 2020. With federal funds dedicated to the effort at that time, the State met its testing goal, providing more than two million tests to Kansans by January 2021. The State of Kansas is grateful for the partnerships that we formed with the commercial and university labs.  

However, once COVID-19 vaccines were approved for emergency use by the FDA, testing rates in Kansas – and across the country – began to decline. Testing rates flattened during the spring and early summer of 2021 across the US. KDHE’s budget for testing was calculated assuming these lower testing rates in the State after the winter surge. 

With emergence of the Delta variant in 2021, testing rates rose significantly By July, Delta became the dominant variant accounting for more than 90% of new COVID cases in Kansas. Statewide tests increased from an average of under 2,000 tests per day in June to an average of nearly 20,000 per day in September.  

Kansas state-funded testing also increased from an average of nearly 800 tests per day in June to an average of nearly 5,000 tests per day in September. The monthly cost of the state-funded testing program grew from approximately $4M in June to approximately $16M in September. This drained the state’s testing budget. Without changes to the testing program, KDHE would have depleted all available funds for testing well before the end of 2021. 

Widespread COVID-19 vaccination will prevent serious illness and death, but the virus is expected to continue to circulate in the population, not unlike the flu. It will be a shared responsibility to protect ourselves and our communities against its spread, which means testing will remain a critical tool to identify the virus.  

Testing will also become an increasingly important way in which those who choose to remain unvaccinated may still be able to work, attend events, and travel. More businesses and employers are requiring proof of vaccination or demonstration of a negative COVID-19 test. 

Given this increased and ongoing need for testing, funding for testing is no longer sustainable by public health alone. This will mean individuals, employers, and health insurers are going to be increasingly asked to pay for COVID-19 testing, as they would with testing for any other communicable disease.  

2. What organizations are impacted by the change to KDHE’s testing strategy?

KDHE has identified six actions to transition to lower cost testing options and is just beginning outreach to stakeholders and labs to provide guidance and ensure a smooth transition.

• Long term care facilities (LTCFs) will be offered the option to use a national vendor
  (Battelle) that has a federal contract and can provide free surveillance testing at no cost to the State or LTCF. LTCFs can also work with their current vendor (e.g. MAWD, KU, 4M, CRL) to establish their own payment arrangements. KDHE will discontinue reimbursement for testing at private contract labs.
• Moving our free community testing sites from WellHealth to our state lab (KHEL) - which is able to offer free community testing at less than half the cost.
• Close enrollment for new organizations into the state-funded employer testing program. Limit the program to organizations currently enrolled and phase out the program after Q1 of 2022. No other states that we are aware of have paid for employer testing in the same way as Kansas.
• Shift the majority of the community testing partners (CTP) program to support antigen testing only, as supplies are available. Move PCR processing for select CTP sites from private contract labs to the state lab - which can again provide more affordable test processing.
• Request that vendors bill insurance for diagnostic testing. Private health insurance has been paying for testing throughout the pandemic, however they may only pay for testing for those who have symptoms or have been exposed to someone with COVID-19. They are not required to pay for employer testing or public health surveillance testing.
• KDHE is collaborating closely with key stakeholders during this transition period.

3. Is this related to the Employer Testing Playbook announced October 26th, 2021?

Yes, as COVID-19 testing becomes an increasingly normal part of our routine, funding for testing should be like any other kind of testing – paid for predominantly through health insurance or via employers¹. The next phase of the unified testing strategy will require KDHE to reduce its costs for testing. 

KDHE is committed to working with our community partners – to include commercial and university labs, businesses, and health plans – to prepare for the next phase of the pandemic. 

1. EEOC guidance strongly suggests that the ADA requires employers to cover the costs of COVID-19 testing. The EEOC’s Enforcement Guidance on Disability-Related Inquiries and Medical Examinations of Employees Under the ADA provides that an employer must pay for all medical-exam related costs when an employer requires the examination because the employer reasonably believes the employee poses a “direct threat.” According to the EEOC, “COVID-19 poses a direct threat.” Therefore, the ADA would require an employer to cover the costs of diagnostic testing related to keeping that direct threat out of the workplace.

4. What is the timeline for implementing these changes to the Unified Testing Strategy?

KDHE is working with various stakeholders to implement immediate changes to the testing program over the month of November, while ensuring a smooth ramp down and transition of the employer testing program by the end of Q1 2022.  

5. How will these changes impact testing availability across Kansas? 

KDHE remains committed to supporting access to testing for all Kansans. Kansans can access a full list of sites offering free testing at http://www.knowbeforeyougoks.com 

Free testing will continue to be available via the options listed below, based on need and the availability of state and federal funding: 

• Mass testing sites: Free PCR testing will continue to be available at mass testing sites in Johnson, Wyandotte, Douglas, Sedgwick, Shawnee, and Riley counties. Find more FAQs specific to mass testing.
• Community Testing Partners and Volunteer Testing Partners: Free rapid antigen test will continue to be offered by over 100 partner organization enrolled in the program in more than 80 counties across Kansas, as supplies are available. Find more FAQs specific to community and volunteer testing.
• Local Health Departments: KDHE will continue to support Local Health Departments that offer free COVID-19 PCR tests to Kansans in their communities. Find more FAQs specific to local health departments..
• K-12 schools: KDHE will continue to fund free testing for students and staff at K-12 schools that are participating in the school testing program. Schools wanting to enroll in the school testing program can contact Sarah Allin. Find more FAQs specific to K-12 schools.
• Outbreaks: KDHE will continue to offer free testing in response to outbreaks in a facility of organization. Find more FAQs specific to outbreaks.

In addition to KDHE free testing sites, Kansans can receive free testing at pharmacies and retailers that are part of the federal Increasing Community Access to Testing (ICATT) program.

Other options for testing include pharmacies, primary care provider clinics, and FQHCs, noting some may require insurance. Individuals can also purchase over the counter tests at many retail grocery stores and pharmacies across Kansas.

6. Will the state lab have the capacity to process the additional tests that this plan will require?

KHEL has increased its testing capacity to handle additional volume. KHEL can comfortably handle 4,000 tests per day and during surges can quickly ramp up operations to support up to 7,500 tests per day.

7. How will KDHE maintain capacity for testing in case of a surge in COVID-19?

KDHE will continue to monitor COVID-19 disease prevalence by identifying and tracking COVID-19 disease activity in communities, testing for COVID-19 variants, and maintaining a wastewater surveillance program.

KDHE will maintain constant engagement with commercial and academic lab partners to support knowledge transfer, surge capacity efforts, and the development of new types of tests.

8. Where can I find FAQs specific to the type of testing program?

Find FAQs specific to the type of testing program.