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Business Continuity Resources for Reopening Healthcare Services

Connie Christian, MBA, CPHRM
KAMMCO Facility Risk Management & Patient Safety Advisor
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States are starting to reopen as stay-at-home orders resulting from the COVID-19 pandemic begin to ease. Unfortunately, reopening likely will not be an immediate return to business as usual. For providers who render non-emergent services and procedures, many offices closed and elective procedures were postponed due to the pandemic. At the same time, the healthcare industry faced a surge in necessary emergency/hospital care, creating a different impact in various sectors of the industry. It is critical that providers carefully restart operations as they address COVID-19-related challenges. 
The Centers for Medicare and Medicaid Services (CMS) has issued Phase 1 recommendations for reopening non-emergent service lines with strong encouragement to continue telehealth modalities and social distancing.

CMS states in its recommendations:
“…non-COVID-19 care should be offered to patients as clinically appropriate and within a state, locality, or facility that has the resources to provide such care and the ability to quickly respond to a surge in COVID-19 cases, if necessary. Decisions should be consistent with public health information and in collaboration with state public health authorities. Careful planning is required to resume in-person care of patients requiring non-COVID-19 care, and all aspects of care must be considered.”[1]

Phase I guidance leaves significant discretion in the hands of providers to determine when, and which services, to reopen. Many national and specialty-specific associations have echoed the CMS guidelines with considerations for reopening and for patient care prioritization coupled with the following:

  • Availability and conservation of personal protective equipment
  • Availability of workforce across the phases of care
  • Facility readiness
  • Medical supply availabilityTesting capacity
Comprehensive communications and marketing plans around reopening of services will be important for providers, staff, and patients.

Facilities and practices may want to communicate:
  • What services have resumed and which services are available in each location – if there are multiple service locations.
  • ‚ÄčThe facility or practice’s comprehensive safety program ensuring patient and staff safety is the top priority.
  • The prioritization of scheduling and training of staff for rescheduling services to focus on COVID versus non-COVID-related appointments or procedures. Absent the areas that have been hit hardest by the pandemic, roughly two thirds of US states are allowing facilities and medical practices to reopen with the remainder set to open their doors within the next several weeks. However, it is the virus itself that will determine whether or not these re-openings are permanent. Each facility and practice should be prepared for a resurgence of the novel coronavirus in their community.

Reopening Resources for Facilities & Provider Practices

Centers for Medicare & Medicaid Services
OPENING UP AMERICA AGAIN Recommendations Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare: Phase I

American Medical Association
COVID-19: A Physician Practice Guide to Reopening

American Dental Association
COVID-19 Center for Dentists

American Hospital Association & Others
Roadmap for Safety Resuming Elective Surgery as the COVID 19 Curve Flattens

Medical Group Management Association
COVID-19: Medical Practice Reopening Checklist

Occupational Safety & Health Administration
Guidance for Healthcare Workers and Employers

Dentistry Workers and Employers
[1] OPENING UP AMERICA AGAIN Centers for Medicare & Medicaid Services (CMS) Recommendations Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare: Phase I, 4/19/2020
This information should not be interpreted as medical or legal advice. Because the facts pertaining to your situation may fluctuate, or the laws in your jurisdiction might vary, please contact your attorney if you have questions related to your legal or medical obligations or rights, state or federal laws, contract interpretation, or other legal questions.