Update: Proposed TB Rule Changes for AFHs
We want to update you on where things stand with the state’s proposed tuberculosis (TB) screening rules and what we are continuing to communicate on your behalf as adult family home providers.
Why these rules are being updated
The department first started this TB rule project in 2017, initially focused on nursing homes. Work paused during the COVID‑19 public health emergency and then restarted in 2024 with the goal of applying updated TB requirements across all long‑term care settings, including adult family homes. Over the years the project has been handed between different staff and has grown more complex than originally intended.
The AFH Council went into this process asking for narrow changes that would make life easier for AFHs. For example, allowing staff who move from one adult family home to another within a certain timeframe to carry their TB clearance with them instead of being re‑tested every time. What has come back is a broader rewrite that adds new screening steps, education requirements, and more.
What the department is proposing
At the most recent stakeholder meeting, the department described their goals roughly as follows:
Require a baseline TB screening process for all staff, including a risk assessment, symptom review, and a test (blood or skin), unless the staff person meets criteria for no testing (for example, a documented negative test within the last 12 months or a documented past positive).
Add TB education requirements, at least annually, so staff know TB symptoms and basic infection control expectations.
Clarify what happens when there is a positive TB test, including expectations around chest x‑rays, symptom review, and following the individual’s healthcare provider recommendations.
Expand the new‑hire timeframe for completing screening from 3 days to 30 days, with the intent of easing timing pressure and recognizing that many staff move between facilities.
What we are pushing back on for AFHs
- From an adult family home perspective, we are raising several concerns:
Complexity and confusion. The draft rules are difficult to follow. Cross‑references between sections, overlapping roles for CDC, DOH, and local health jurisdictions, and shifting terminology (screening vs testing) make it hard to see what AFHs are actually required to do in real‑world scenarios.
Mismatch with the AFH model. Adult family homes are small, home‑ and community‑based settings, often with one or two primary caregivers for six residents. Most providers are not medical professionals. Requirements that may be feasible in a nursing home with a medical director and on‑site RNs become burdensome and confusing when applied to AFHs.
New annual requirements that will drive citations more than safety. Adding a standalone annual TB education requirement is very likely to become “one more date to miss,” especially for one‑ or two‑person operations. We have been clear that this is more likely to increase citations than to meaningfully reduce TB risk.
Staffing impacts of pre‑work testing. While expanding the testing window from 3 to 30 days is helpful on paper, we are concerned about any rule that requires testing to be fully completed before a new staff person can work with residents. In communities already facing severe staffing shortages, this could leave homes unable to cover shifts for weeks while waiting on tests or x‑rays.
Access barriers to TB testing and x‑rays. Many providers report that:
Local clinics stopped doing TB testing during COVID and have not restarted.
Staff in rural areas and on islands must travel long distances or take ferries to get tests or x‑rays.
Occupational health and primary care providers are increasingly refusing to order chest x‑rays for asymptomatic people with a prior positive test, citing concerns about unnecessary radiation and conflicting guidance.
What happens next
The department has acknowledged that the rules are not finished and has committed to:
Revising the draft rules to simplify language and reduce some of the confusion.
Considering alternative timelines and structures, including feedback from AFH providers and other associations.
Asking DOH to see if they can participate in future stakeholder meetings so the associations can provide context and ask questions.
Issuing another draft of the rules.
Scheduling another meeting.
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