NEW COVID-19: Returning to Practice Guide
Here are frequently updated resources to help you safely return to an office-based practice while guarding against COVID-19 risks. Developed by your ProAssurance Risk Resource team, this online guide will help aid you in preparing your practice and educating your employees for a safe transition.
Many public health authorities are beginning to issue guidance allowing for the reopening of certain businesses. In evaluating the appropriate time to open a medical practice, strong consideration should be given to potential health risks to patients and employees by resuming operations. Practices need reliable testing capabilities, personal protective equipment (PPE), physical environment adaptations, and operational modifications to meet these goals. Refer to this updated COVID-19: Returning to Practice Guide for assistance in evaluating readiness to reopen.
- Keep in touch with staff (conference call, virtual meeting, etc.). Concern for staff's well-being is an important aspect in developing a culture of safety. Evaluate the need for family support to enable staff to return to work.
- Evaluate staffing needs in light of anticipated patient demand. Discuss any employment changes with human resources, if available, or your legal counsel. The Centers for Disease Control and Prevention (CDC) offer a resource for strategies to Mitigate Staffing Shortages.
- Adapt work schedules as required (e.g., full staff, skeleton staff, staggered hours, etc.)
- Provide employees with resources to manage pandemic-related stress and anxiety effectively
- Develop a staffing plan for employee illness and absence
- Advise employees concerning circumstances under which they should not report to work
Business and Compliance
- Stay informed. Visit your state and local health departments' websites often for updates regarding testing and contact tracing.
- Designate a Compliance Officer to monitor regulatory developments
- Medicare Provider Relief Fund recipients should contact accountant or attorney to ensure program compliance
- Identify current capabilities of specialty referral sources
- Contact vendors such as sales representatives, suppliers, environmental services, property manager, and EMR company
- Review updated reimbursement guidelines for third party payor
- Anticipate possible medication shortages
*Last updated 4/28/2020
Facility and Supply Considerations
- Clean and thoroughly disinfect environment of care prior to re-opening facilities
- Reconfigure office space to comply with social distancing guidelines
- Perform equipment, supplies, and on-site medication checks, including vaccines and immunizations, for expiration dates. Test and inspect all equipment, including emergency equipment.
- Inventory PPE and develop contingency plans as necessary
- Review infection prevention policies, update polices as necessary
- Refer to the CDC’s Strategies to Optimize the Supply of PPE and other Equipment for additional considerations
Triage and Patient Flow
- Consider using CDC Scripting guidelines for telephone screening
- Implement alternative triage options such as telemedicine or drive through assessment
- Designate a screening area specifically for evaluating patients presenting with fever or respiratory associated symptoms
- Complete documentation in a clean area outside of exam room
- Cross train employees as appropriate
*Last updated 4/28/2020
- Provide staff education about COVID-19 infection control
- Educate staff and patients about changes they can expect to be implemented in the office
- Re-evaluate delegating job responsibilities during emergency periods.
- Reiterate customer care standards and patient expectations
- Refer to the CDC’s Train and Educate Healthcare Personnel resource for additional considerations
- Review safety practices for essential providers returning to work. The CDC has released criteria for personnel with suspected or diagnosed COVID-19.
*Last updated 4/24/2020
- Verify FDA approved testing is locally available
- Determine whether and how often to test employees
- Understand that not all testing methods yield reliable results. Select an available method that is shown to produce the fewest false results.
- Work with your state and local health departments on diagnostic testing protocols and procedures
- Educate your staff on legal requirements to report COVID-19 testing results to public health officials
- Confirm all labs and other diagnostic testing services are operational, along with
- the availability and timeliness of results
- Prioritize follow-up of critical diagnostics
- Ensure follow-up of diagnostic testing, labs, and postponed surgeries prior to
- Refer to the American College of Surgeons for these resources: Local Resumption of Elective Surgery Guidance and Roadmap for Resuming Elective Surgery after COVID-19 Pandemic
*Last updated 4/28/2020
- Physicians/providers should review their schedules to prioritize visits for chronic, acute, and well patients
- Review schedule for postponed elective surgeries, biopsy callbacks, follow-up specialty referrals, lab results, annual physicals, and routine screenings, such as mammography, colonoscopy, and telemedicine visits
- Consider pre-visit telephonic screening of patients
- Schedule sick and well visits at alternate times
Last updated 4/24/2020
Policies and Procedures
- Continue to use and enforce social distancing guidelines
- Develop and/or review plans that reduce the number of staff caring for suspected/confirmed cases, create protocols, and determine isolation requirements
- Adhere to CDC guidelines regarding home isolation pending test results
- Educate employees on prevention and transmission of infectious disease
- Assume everyone is a carrier
- Educate employees on collecting and handling specimens
- Consider methods to reduce exposure by shielding employees and other patients from infected individuals
- Consider alternate entrances for symptomatic patients, and request patients wait in their vehicles until called by staff. Provide clear signage & directions.
- Discontinue use of toys, magazines, and other shared items in waiting areas, as well as office items shared among patients, such as pens, clipboards, phones, etc.
- Review frequency and scope of office and medical cleaning. Disinfectants are necessary in the medical practice, and many are approved for use against coronavirus.
- Post signage in commonly encountered languages that educates patients about proper respiratory hygiene, including sneeze and cough etiquette. Remind patients to use proper handwashing techniques.
- Provide alcohol-based hand sanitizer, surgical masks, gowns, and disposable gloves to all caregivers and staff who must be within six feet of patients
- Instruct patients to wear a face covering to appointment. Provide a face covering to all patients who arrive without one.
- Purchase single use towels, tissues, and mops for use throughout the office
- Use no touch waste baskets with disposable liners
- Place alcohol-based hand sanitizer throughout the office
*Last updated 4/28/2020
Regulations and Reimbursement
- Consult state regulations and status of emergency licensure orders
- Review HIPAA obligations applicable to telemedicine, as regulations have been altered for current emergency conditions and Health and Human Services policies that may have been altered for COVID-19
- Refer to third party reimbursement requirements
- Review Medicaid and Medicare coverage questions
Planning and Implementation
- Identify technology that you already have and determine if expansion or improvements to your system are needed
- Plan the telehealth workflow
- Inform patients of the availability of telehealth services
- Verify patients are tech-ready (e.g., reliable internet access, smartphone, tablet, etc.). Technological fluency and internet-access limitations of a patient population may limit the efficacy of telemedicine.
- Identify presentations or conditions for which telemedicine provides an appropriate initial assessment
Patient Communications and Informed Consent
Although some states specifically regulate the process for informed consent in telemedicine, there are a number of general factors a physician should consider when obtaining that consent, such as the nature of the patient’s condition, confidentiality, and the technological capabilities necessary.
In this video, Senior Risk Resource Advisor Mallory Earley discusses the process for obtaining informed consent when practicing telemedicine. Watch the video on YouTube.
Download and adapt the sample form, Telehealth Informed Consent Form During COVID-19 Pandemic, also available at ProAssurance.com/SampleForms.
- Conduct and document an informed consent discussion outlining telemedicine restrictions
- Explain telemedicine visits may limit the ability to diagnose certain conditions
- Follow-up with patients from virtual visits during emergency period, prioritize new patients
- Follow standard documentation practices with all telemedicine encounters
- Develop a system to identify and monitor patients requiring subsequent in-person evaluation and treatment (i.e., recall, tracking, follow-up)
- In states without independent practice regulations, physicians supervising allied healthcare professionals should document training of all supervised clinicians in the use of the chosen telemedicine platform
- Develop policies and procedures if you plan for long-term telemedicine use
- Notify agent or underwriter if you plan to continue the practice of telemedicine
- ATA’S Quick-Start Guide to Telehealth during a Health Crisis (register to download)
- Telehealth.HHS.gov for Providers
- Centers for Medicare & Medicaid Services General Provider Telehealth and Telemedicine Tool Kit
- ProAssurance’s Telemedicine Best Practices Guide and YouTube Video Series
Last updated 5/15/2020
With COVID-19, patients and staff are stretched to their limits, and documentation may suffer as a result of rushed, less detailed, and error-prone entries. While electronic medical record (EMR) workarounds may seem like the fastest way to capture information, use caution to maintain an accurate chart. These steps may help improve comprehensive documentation during the COVID-19 pandemic.
- Consult the ProAssurance Risk Resource Guidelines to review documentation fundamentals, available on the secure services portal
- Develop a screening policy (i.e., temperature, cough, difficulty breathing, new loss of smell and taste) to identify high risk patients. For patients exhibiting signs and symptoms compatible with COVID-19 follow state and local health department guidelines for testing
- Document screening information in the patient’s medical record. Consider creating a template with other relevant screening criteria, such as: travel history, on-site hand sanitizing, and face mask compliance for long-term use in the practice
- Current conditions make informal modes of communication more attractive to clinicians. All patient interactions, regardless of the mode of communication, should be recorded in the medical record
- Medication reconciliation documentation should include all new medications, dosing changes, all discontinued medications, supplements, and medications prescribed by others
- Consider a template to consistently document staff use of PPE, social distancing, and other appropriate precautions
- Record evidence that routine preventive screening and services (i.e. colonoscopy, mammogram, etc.) were offered in accordance with the organization’s practice guidelines. Document patients’ refusal to comply with clinician recommendations
- Provide training on all EMR platforms to employees whose responsibilities have expanded to include documenting in patient charts. Document this training with an employee skills checklist
- Correct errors and addenda, per best practices guidelines
- In the event of a claim occurring during the pandemic, keep a record of all regulatory changes and waivers issued by federal and state agencies
Last updated 5/27/2020
- Reflect on performance strengths and weaknesses in order to identify opportunities in process improvement and patient safety
- Conduct ongoing quality reviews and self-evaluations
Last updated 4/24/2020
*Drawers marked with an asterisk have been updated since 5/27/2020.
COVID-19 State Guidelines for Returning to Practice
Get up-to-date information on guidance and requirements states have issued on returning to full-time practice as social distancing restrictions are lifted.
Contact your ProAssurance Risk Resource team at 844-223-9648 or RiskAdvisor@ProAssurance.com for additional assistance, Monday – Friday, 8:00 a.m. – 5:00 p.m., ET/CT
Return to Practice Video
COVID-19 Information Center