In response to questions from Richard Leonard on Thursday, Nicola Sturgeon said that figure was not available due to it being connected to “clinical decisions”.
The Scottish Labour leader said health secretary Jeane Freeman had said it was happening in a very small number of cases, and suggested it would “make sense” for the Scottish Government to be monitoring such discharges.
He said: “This week, we have been told by the Cabinet Secretary that people will only be admitted to care homes following a positive test if ‘it was in their clinical interests and following a risk assessment’.
“She also said that this was happening only in a very small number of exceptional cases. First Minister, how many cases is it?”
Ms Sturgeon replied: "I can’t give that information because these are clinical decisions taken by clinicians.
“The policy is very clear. If somebody is in hospital for a Covid-related reason, they require to have two negative tests before being discharged to a care home.
"If they are in hospital for a non-Covid reason, they still require a negative test.
"That is the policy in any situation. I have had lengthy discussions with the Chief Medical Officer and clinicians about this.
"In any policy there are ethical reasons and clinical reasons why there has to be exceptions in some circumstances.”
Mr Leonard responded: "If the Cabinet Secretary for Health describes it as a very small number, I would have thought it would make sense for the government to monitor the number of Covid-positive and untested patients being discharged to care homes.”
The First Minister was also asked whether she would provide all correspondence and evidence to the Crown Office if asked to do so in relation to their ongoing investigation into care home deaths, ‘Operation Koper’.
Ms Sturgeon said such a question would be a matter for the Crown Office and it would be “completely wrong” for her to comment and potentially influence the outcome of the investigation.
She said: “The government acted in a way that was intended to protect the population and protect those as much as possible.
"I have never, ever stood here and suggested that there were not things we got wrong, in the face of a new virus where the challenges were significant.
"We have sought to learn as we have gone along, we have changed policy and we have changed practice.”
However, Mr Leonard responded by saying: "I don’t think it would prejudice the investigation to give a commitment that all evidence and all correspondence without reservation would be made available.”
Earlier this week, the Crown Office was asked by this newspaper whether it would interview civil servants or members of the political Cabinet in connection to Operation Koper.
In response, it said it would not provide commentary on an ongoing investigation and refused to answer the question.
The First Minister’s comments came as she announced a further 51 deaths from coronavirus in Scotland and another 1,225 positive tests.
Ms Sturgeon said the figures meant the death toll now reads 3,639, with 1,125 people battling the virus in hospital, with 90 in intensive care, down by 31 and up by six respectively.
She said the R number, which states the average number of people one infectious person would infect, was “still slightly below one”.
This indicates restrictions are “having an effect”, although Ms Sturgeon added: “We want infection rates to come down further and faster.”
The First Minister was also challenged by Scottish Liberal Democrat leader Willie Rennie on the difficulties faced by the families of care home residents who are being denied access.
Mr Rennie raised several cases including one family member of a care home resident who said: “Every conversation, Mum tells me how she wants to die.”
He said: “We know that visits can be done safely and I know that the First Minister cares, but the families just want action. Time is running out.
"Why do families have to wait for yet more weeks before they have the slender prospect of seeing their loved ones?”
Ms Sturgeon said the Scottish Government was attempting to “navigate our way carefully” through a “difficult, and for many people, dangerous” period, adding the restrictions were in place to reduce the risk of the infection spreading and impacting care homes.
Responding to concerns testing of families was still “weeks away”, the First Minister said “we have to be careful to get the situation on testing right”.
Ms Freeman announced on Wednesday all care homes would have access to quick ‘lateral flow’ Covid-19 tests for visitors over the Christmas period.
The health secretary said an initial roll-out will begin with 12 care homes across four local authority areas from December 7.
However, Mr Rennie said he was “frustrated” by the delay to the expansion of testing to families of residents in care homes.
He said: “It will be weeks before families will be tested so that they can get access to loved ones in care homes. It is just not good enough. The effects of the Government’s reluctance to embrace testing at the beginning are being felt now."
The First Minister replied she was not “reluctant” to do anything that could help tackle Covid-19 and she was “frequently frustrated things cannot go more quickly”.
She said: “Often, these things are more complex than they appear.
"We have to ensure that the use of testing, important though it is, is part of a bigger approach and does not inadvertently undermine some of the other important messages that we are trying to get across.
"There are big things at stake – not least human health and life – which is why we take the decisions as seriously as we do.”