July 22, 2020
As some states have begun relaxing their stay-at-home orders and are gradually reopening businesses, you may be preparing to reopen your practice as well. As a long-time compliance expert and practice management consultant, I thought I would offer a few thoughts regarding the challenge of reopening your practices. You must create a plan for reopening that minimizes the potential for transmission of COVID-19, via cleaning and social distancing, via steps to ensure patient and staff compliance with new protocols, and via aggressive screening. The plan should also check the usual compliance boxes in terms of having appropriate written policies in place, revising them if necessary, and reviewing your liabilities in case someone does claim to contract COVID-19 at your practice.
Below is a list of action items you should consider taking before re-opening:
There needs to be a process in place for the end of each day regarding cleaning of the facility with proper sanitizers/disinfectants.
When it comes to cleaning your facilities, Professional Cleaning (ServePro) is offering a very deep cleaning at a discount. Even better, they provide a certificate for the sterilization and disinfection procedures they use.
Have a reopening plan that is specific to your area's COVID-19 situation. Consider an incremental reopening if you are in a low-impact area; at a minimum, you need to have non-PPE supplies, such as surgical masks, cloth masks, proper cleaning supplies, etc.
Have written policies that are reasonable and flexible so that your staff and patients have an easy time complying with the requirements.
Have a plan for dealing with non-compliant employees and/or patients who refuse to wear a mask or are found taking it off throughout the course of the day or patients who show up without a facial covering or with their children who are not being seen.
Post your OSHA poster in a conspicuous area to demonstrate proper safety measures for patients and staff.
Check with your local, state, and the federal government for compliance requirements (Executive Orders) that detail the type of surgical procedures your practice can furnish, especially if you are in a "Hot Zone."
Make sure you have written policies in place for outbreak(s), pandemics, and/or emergencies (medical liability, privacy, safety, disaster recovery, etc.).
Contact your Medical Liability Insurance Carrier to discuss if and how your front-line providers, those who treat patients with potential COVID-19, are protected. Congress has shielded providers from liability in certain instances (see section 3215 of H.R.748 - CARES Act).
Consider implementing a telephone triage program to avoid unnecessary patient visits to the practice leading to opportunities for potential exposure.
Screen all patients and employees each day prior to entering the building. Ask appropriate questions regarding self or mandated quarantine, travel during the past 14 days to another state or country, their mode of transportation (i.e. personal car, train, plane, etc.), whether they have been exposed to COVID-positive individuals, and if you have thermometers, take their temperature. Make sure you document everything and have patients and employees sign an attestation form to indicate the information they provided is accurate to the best of their knowledge.
As always, I am either working to create something or I try to find something that is top-notch so I do not have to recreate the wheel. The American Academy of Family Practitioners (AAFP) has created a great "Checklist to Prepare Physician Offices for COVID-19." While the document is only four (4) pages long, it is very comprehensive and you can use it to create a checklist that is the right size and fit for your practice. Stay healthy and well!