Guidelines for Practicing During a Pandemic
Strong consideration should be given to the potential health risks encountered by patients and employees during a pandemic.
Below you’ll find frequently updated resources to help you understand how to reduce risk and improve patient safety while managing your practice during COVID-19. This online guide will help aid you in preparing your practice and educating your employees.
Your ProAssurance Risk Management team will continue to monitor the pandemic and provide updates and recommendations as conditions evolve.
- Obtain training on Administration, Storage, Handling, Safety, and Reporting of the COVID-19 vaccines.
- Refer to Governmental Guidance and the ADA on Pandemic Preparedness in the Workplace
- Review federal reimbursement guidelines related to vaccine administration.
- Develop a strategy to address vaccination concerns.
- Vaccination Q&A Risk Management Concerns
*Last updated 10/1/2021
Culture of Safety
- The leadership team plans and implements a strategic vision for the organization. Leaders have the opportunity to encourage and reinforce clinical risk management with every employee, contractor, and clinician.
- Prioritize a culture of safety that will mitigate professional liability risk and enhance resident confidence.
- Leadership establishes a culture of safety through performance improvement, physician and staff engagement, and providing quality clinical care.
- Encourage participation in patient safety education and training for medical staff and employees and support development of new risk mitigation initiatives.
- The AHRQ culture survey helps identify areas needing improvement, and provides tools to enhance the culture of safety.
- Establish a chain of command (COC) protocol that empowers all employees to raise any perceived patient safety concerns with leadership without fear of retribution. Additional resources are available to assist leadership in developing a chain of command protocol, including: a sample policy and chain of command flowchart.
- Provide staff education about COVID-19 infection control.
- Educate staff and patients about office pandemic infection control protocols.
- 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 after suspected or confirmed COVID-19. The CDC provides interim guidance on return to work criteria for healthcare personnel with suspected or diagnosed COVID-19.
- Keep updated on current recommendations for expectant mothers and the pediatric population concerning COVID-19 risks.
- Refer to Governmental Guidance and the ADA on Pandemic Preparedness in the Workplace.
Considerations for the workplace regarding HIPAA and COVID-19 HIPAA, COVID-19 Vaccination, and the Workplace
*Last updated 10/20/2021
- Stay current on testing options available to patients.
- Verify FDA authorization status of testing utilized or recommended.
- Determine testing protocols for healthcare personnel.
- Understand that diagnostic test reliability varies depending on testing method utilized and timing.
- 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
- Study updated guidance on safely performing surgical procedures as cases of COVID-19 surge in healthcare facilities across the country.
In this video, Senior Risk Resource Advisor Laurette Salzman discusses how to adjust tracking systems to address changes in patient scheduling and patient flow models. Watch the video on YouTube.
*Last updated 10/1/2021
- 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
- Adjust scheduling to minimize exposure during healthcare delivery.
Last updated 10/1/2021
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.
Preview A Comprehensive Approach to Physician Wellness on YouTube. In this video, Senior Risk Resource Advisor Mallory Earley discusses the process for obtaining informed consent when practicing telemedicine.
Sample Telehealth Informed Consent Form During COVID-19 Pandemic
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
- 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 10/1/2021
The efforts to prevent the spread of COVID-19 amount to an unprecedented disruption in nearly every facet of daily life. These disruptions inevitably affect the psychological wellbeing of both patients and the healthcare workforce. Physicians should anticipate a greater need for mental health resources, and plan to address the needs of patients and staff. Below are some strategies you can adapt to help meet these mental health needs:
- Become familiar with available national and local mental health resources
- Initiate dialogue regarding the pandemic's impact on patients’ stress, and direct those susceptible to available resources
- Consider patient vulnerability to high-risk stressors such as job loss, homeschooling, and lack of childcare
- Know when a referral to a mental health specialist would be appropriate, and add basic mental health screening questions to your patient assessment
- Cultivate collaborative care referral sources in mental health disciplines, who may be willing to see patients in need on an expedited basis
- Follow-up on behavioral health and social service referrals
- Understand stay-at-home requirements have eliminated outside safe havens for patients vulnerable to domestic abuse and neglect. Evaluate pediatric, adult, and geriatric patients' need for protection.
- Older patients may be particularly susceptible to pandemic-related depression, especially those quarantined in isolation. Consider resources available to provide these patients with social connection.
- Ensure treatment plans, referral communications, and education are documented in the medical record
- Educate staff that certain patients are subject to stereotyping concerning COVID-19 transmission. Staff awareness of patient sensitivities may aid in providing effective patient care to all
- Children may interpret and respond differently to stressful events. Be prepared to address these unique needs with caregivers
- Give consideration to health literacy variations among your patients
In this video, Senior Risk Resource Advisor Tina Reynolds discusses how to recognize and address limited health literacy when communicating with patients. This can be especially helpful for conveying COVID-19 prevention and treatment information. Watch the video on YouTube.
- Create an atmosphere in which employees can freely express concerns about personal wellness and the pandemic's impact on work performance
- Ask employees how they are coping with the pandemic's demands. Listen and empathize without making judgments
- Recognize a fundamental principle of staff care is that employees should feel valued, appreciated, and supported
- Acknowledge that providing care during the pandemic is stressful to staff members. Suggest appropriate stress mitigation techniques to assist staff in coping. View our new online seminar for insureds, A Comprehensive Approach to Physician Wellness for recommendations.
Preview A Comprehensive Approach to Physician Wellness on YouTube.
- During the pandemic, ProAssurance-insured physicians and insured advanced practice healthcare providers can receive confidential, non-reportable coaching, compliments of ProAssurance.
Last updated 8/13/2020
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) with pandemic infection control measures
- 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
Regularly monitor exposure risk in your area to determine whether scheduling changes are required in your practice. Evaluate the exposure risk created by activities in the practice, and modify policies as needed to protect employees and patients. Flexibility is essential in operating your practice, because circumstances of the pandemic are fluid.
Note the following key considerations to determine if further modifications to your practice are required:
- Respond appropriately to staff exposure
- Review infection control process
- Track and follow-up on deferred annual screenings, specialty referrals, and diagnostic tests
- Ensure adequate inventory of PPE
- Capture all patient interactions, regardless of the means of communication, in the medical record
Last updated 8/25/2020
CDC: Vaccine Recipient Education
Healthgrades: State-by-State COVID Vaccine Guide
U.S. Department of Health and Human Services (HHS): HIPAA, COVID-19, and the Workplace
FDA COVID-19 Vaccine News and Updates
Biden-Harris Administration Issues Emergency Regulation Requiring COVID-19 Vaccination for Health Care Workers
Vaccination Q&A Risk Management Concerns.