The Centers for Medicare and Medicaid Services (CMS) has offered guidance for facilities providing elective procedures or "non-emergent, non-COVID-19 healthcare."
The CMS Guidance was issued in connection with the White House's Guidelines for Opening Up America Again.
Although the CMS Guidance encourages the maximum use of telehealth services, it provides recommendations for in-person care of non-COVID-19 patients when care cannot be accomplished virtually. The CMS Guidance applies to facilities in regions with low incidence of COVID-19, and it states that 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.
The CMS Guidance contains a long list of considerations that aim to give healthcare facilities some flexibility in "providing essential non-COVID-19 care to patients without symptoms of COVID-19 in regions with low incidence of COVID-19."
The considerations in the CMS Guidance are as follows:
- Facilities should evaluate the necessity of the care based on clinical needs. Providers should prioritize surgical/procedural care and high-complexity chronic disease management. Select preventive services, however, may also be highly necessary.
- Facilities should consider establishing Non-COVID Care (NCC) zones that would screen all patients for symptoms of COVID-19, including temperature checks. Staff and all others who work in or enter the facility (physicians, nurses, housekeeping, delivery personnel, and others) would be routinely screened.
- Sufficient resources should be available to the facility across phases of care, including PPE, healthy workforce, facilities, supplies, testing capacity, and post-acute care, without jeopardizing surge capacity.
Personal Protective Equipment
- Consistent with the CDC's recommendations for universal source control, healthcare providers and staff should wear surgical facemasks at all times. Procedures on the mucous membranes including the respiratory tract, with a higher risk of aerosol transmission, should be performed with great caution, and staff should utilize appropriate respiratory protection such as N95 masks and face shields.
- Patients should wear a cloth face covering that can be bought or made at home if they do not already possess surgical masks.
- Every effort should be made to conserve personal protective equipment consistent with the CDC's guidance.
- Staff should be routinely screened for symptoms of COVID-19 and, if symptomatic, they should be tested and quarantined.
- Staff who will be working in 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).
- Staffing levels in the community must remain adequate to cover a potential surge in COVID-19 cases.
- In a region with a current low incidence rate, the facility should create areas of NCC that have in place steps to reduce risk of COVID-19 exposure and transmission. These areas should be separate from other facilities to the degrees possible (i.e., in a separate building or in designated rooms or floor(s) with separate entrances and minimal crossover with COVID-19 areas).
- Within the facility, administrative and engineering controls should be established to facilitate social distancing, such as minimizing time in waiting areas, spacing chairs at least six feet apart, and maintaining low patient volumes.
- Visitors should be prohibited. If, however, they are necessary for an aspect of patient care, they should be pre-screened in the same way as patients.
- Ensure that there is an established plan for thorough cleaning and disinfection prior to using spaces or facilities for patients with non-COVID-19 care needs.
- Ensure that equipment such as anesthesia machines used for COVID-19 positive patients are thoroughly decontaminated, following CDC guidelines.
- Adequate supplies of equipment, medication and supplies must be ensured, and not detract from the community's ability to respond to a potential surge.
- All patients must be screened for potential symptoms of COVID-19 prior to entering the NCC facility, and staff must be routinely screened for potential symptoms as noted above.
- When adequate testing capability is established, patients should be screened by laboratory testing before care, and staff working in these facilities should be regularly screened by laboratory test as well.
Colin Luke is partner and member of the board of directors of Waller. Nate Lykins is an associate in the Waller health care practice.