Implementing the Necessary Precautions
As COVID-19 has swept across our nation and stay-at-home orders have been imposed, many practices have been forced to close their offices or significantly limit their patient care. Now, as the nation begins to “reopen”, many practices are tasked with the responsibility of opening their practices up to patients in a safe manner. But what does that mean? What safeguards should be put in place to ensure the safety of practice clinicians, staff, patients and other visitors?
The Centers for Disease Control and Prevention (“CDC”), state and local health departments and professional medical societies have released guidance on precautions that should be taken as practices resume or increase patient visits. Although the guidance materials differ in some respects, there are several common themes which practices should take into consideration when implementing policies for reopening.
Personal Protective Equipment (“PPE”)
The CDC, health departments and professional societies all recommend the proper use of PPE in the office. They recommend clinicians, staff, patients (unless medically inappropriate) and visitors wear face masks or coverings while in the office. For those clinicians and staff with frequent hands-on patient interaction, they recommend use of the N95 respirators. Where there is a shortage of such respirators, the CDC provides specific guidelines for extended use and reuse of such masks, as well as alternatives to the N95 masks (available at https://www.cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy/index.html). Depending on the procedures performed by the practice, other forms of PPE (e.g., face shields, gowns, etc.) may also be advised.
Social Distancing
Even as states and communities reopen, social distancing remains necessary. In the practice, social distancing safeguards should be implemented, which may include, without limitation: (i) limiting the number of patients in the waiting room at any given time; (ii) spacing out waiting room chairs to ensure adequate distancing; (iii) requiring patients to wait in their cars until the physician is ready to see them; (iv) limiting or prohibiting persons from accompanying patients at their visits (unless medically necessary); and/or (v) scheduling patients in a manner to limit patient interaction.
Sanitation
Ensuring a clean office and sanitized equipment are always duties of the practice. That said, those efforts should be increased as COVID-19 continues to pose a threat. High-touch surfaces should be cleaned throughout the day. Exam rooms should be cleaned thoroughly between patients. Magazines and other items which patients may touch should be removed from the waiting room, and pens for patient use should be cleaned after each use.
Clinicians and staff should continue hand-washing and other hygiene practices to limit the risk of transmitting the virus. All staff should have access to hand sanitizer that contains greater than 60% ethanol or 70% isopropanol when hand-washing is not immediately available. Hand sanitizer (or preferably soap and water) should be used any time a staff member coughs or sneezes; after each patient interaction; and when passing items between staff.
Finally, the office should be cleaned thoroughly each night to ensure that any potential trace of the virus is removed before the office reopens on the following business day.
For additional information on recommended safeguards for your practice, review the CDC guidance materials for healthcare providers, available at https://www.cdc.gov/coronavirus/2019-nCoV/hcp/index.html. You should also look to your state and local departments of health and professional specialty societies for guidance tailored to your specific practice. If you still have questions regarding the safeguards and how to implement them in your practice, please contact our firm.