CMS Releases Guidelines for Reopening Health Care Systems

April 22, 2020 Advisory

With the unprecedented impact of the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) recommended limiting “non-essential care” in a March 18 announcement. As parts of the country begin to see a decline in new COVID-19 related cases, CMS has recognized the importance of facilities’ ability to offer care unrelated to the pandemic – elective surgeries, chronic disease care and basic preventive care. It is important to note that this guidance is only for those communities which are in Phase I of the Guidelines for Opening Up America Again as outlined by President Trump.

The guidance strongly recommends continued use of telehealth for treatment and reminds facilities they need to remain able to treat a surge of COVID-19 affected patients should the need arise.

In determining the types of services a facility should offer, CMS suggests each facility consider the following factors:

  1. General Factors – including coordination with local governments; setting up non-COVID-19 care zones (NCC); and prioritizing certain types of care (e.g., chronic care management) over other types.
  2. Personal Protective Equipment (PPE) – developing guidelines for use of PPE by patients and continued use by health care providers at all times.
  3. Workforce Availability – continue to screen staff for symptoms of COVID-19 and, if the facility sets up NCCs, keep staff from NCCs separate from other parts of the facility.
  4. Facility Considerations – review the physical layout of the facility to ensure social distancing requirements are maintained (e.g., removing chairs and minimizing wait times).
  5. Testing Capacity – all patients entering an NCC should be screened for potential COVID-19 symptoms.

The guidance also discusses sanitation protocols and supplies. A complete copy of the guidance can be found online.

Armstrong Teasdale attorneys are actively monitoring and providing updates regarding the impact of COVID-19. For additional information, visit Armstrong Teasdale’s COVID-19 Resource Center.

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