If your area has a low incidence of COVID-19, CMS says you can consider reopening your practice to resume caring for patients who need procedures, chronic disease management, and even preventive care. The agency has released a series of guidelines for restarting healthcare systems in areas with “a low, or relatively low and stable incidence of COVID-19.”

The guidelines are entitled “Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare: Phase I,” and presumably future guidelines will offer additional phases in which some of the restrictive guidelines are relaxed. Below are some highlights of the recommendations:

  • Prioritize surgical/procedural care and high-complexity chronic disease management; however, select preventive services may also be highly necessary.
  • Establish a “Non-COVID Care (NCC) zone” in which all patients are screened for symptoms of COVID-19, including temperature checks. This includes screening staff and everyone who works in the facility (providers, housekeeping, delivery, etc.).
  • Visitors should be prohibited but if they are necessary for an aspect of patient care, they should be pre-screened in the same way as patients.
  • If the organization also handles COVID cases, COVID-specific areas should be established and kept separate from other facilities to the degrees possible (i.e., separate building, or designated rooms or floor with a separate entrance).
  • Staff who will be working in these NCC zones should be limited to working in these areas and not rotate into “COVID-19 Care zones” (e.g., they should not have rounds in the hospital and then come to an NCC facility).
  • Use plenty of Personal Protective Equipment (PPE), including surgical facemasks for healthcare providers and staff, to be worn at all times. CMS recommends better PPE for procedures on the mucous membranes and respiratory tract, including N95 masks and face shields.
  • Patients should wear a cloth face covering or surgical masks to reduce potential for transmission.
  • Establish social distancing rules within the facility, such as minimizing time in waiting areas, spacing chairs at least 6 feet apart, and maintaining low numbers of concurrent patients.
  • Ensure thorough cleaning and disinfection throughout all spaces and facilities.

CMS also warns that any re-opening can be temporary, and that all facilities should “continually evaluate whether their region remains a low risk of incidence and should be prepared to cease non-essential procedures if there is a surge” in COVID-19 cases.

The new recommendations can be found here: https://www.cms.gov/files/document/covid-flexibility-reopen-essential-non-covid-services.pdf

The Guidelines for Opening Up America Again can be found here: https://www.whitehouse.gov/openingamerica/#criteria

Sean M. Weiss is a Partner and serves as VP/Chief Compliance Officer for DoctorsManagement, LLC based in Knoxville, TN. DoctorsManagement, LLC services more than 20,000 clients nation-wide and has been in existence since 1956. Weiss serves as an Investigator and expert witness in Federal and State cases as well as an expert or lead in Administrative Law Judge Hearings. During his 25-year career, Weiss has engaged in more than 200 cases working with law firms and health systems across the country. Weiss serves as a third-party compliance and regulatory officer for more than a dozen health care organizations across the country of varying sizes. For more information on Sean M. Weiss or DoctorsManagement, LLC visit us online at www.doctorsmanagement.com or contact us directly at 800.635.4040. You can also follow Sean on his biweekly Blog on LinkedIn (Sean M. Weiss “The Compliance Guy”) or at www.thecomplianceguyblog.com

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