Timely estimation of the current value for COVID-19 reproduction factor $R$ has become a key aim of efforts to inform management strategies. $R$ is an important metric used by policy-makers in setting mitigation levels and is also important for accurate modelling of epidemic progression. This brief paper introduces a method for estimating $R$ from biased case testing data. Using testing data, rather than hospitalisation or death data, provides a much earlier metric along the symptomatic progression scale. This can be hugely important when fighting the exponential nature of an epidemic. We develop a practical estimator and apply it to Scottish case testing data to infer a current (20 May 2020) $R$ value of $0.74$ with $95%$ confidence interval $[0.48 - 0.86]$.
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