Healthcare

Since the onset of the coronavirus public health emergency, the healthcare industry has experienced exceptional pressure and been challenged in ways unlike ever before. Although the need for patient care has significantly increased in some areas, particularly for hospitals, other healthcare providers have seen some or all of their patient services suspended as a result of the need to reserve care for only essential circumstances and governors’ non-essential business orders or shelter-in-place precautions.

As the essential care restrictions ease across the country, healthcare providers must continue to monitor federal, state, and agency guidelines for resuming patient procedures. As part of that process, providers must consider short-term and long-term plans for general legal and regulatory compliance, health and safety measures for patients and staff, and overall business integrity. While it may be no easy task to remain consistent with the constantly evolving guidelines issued for delivery of care, employment, and business operations, those providers that prepare now for the return to business operations will be best positioned for success. The following list of considerations are offered as a reference guide for healthcare providers as they prepare to begin offering non-essential care during the on-going public health emergency and seek to revamp services where necessary in the months to follow.

• Adhere to available health and safety guidance
  • Designate a point person to monitor guidance, and update employees / staff regularly
  • Review and implement federal, state, third party, and industry specific guidance as necessary
    • See White House guidelines for Reopening America and CDC employer guidelines
• Maintain standard legal and regulatory compliance
  • Ensure all business licenses, registrations, and permits are current and valid
  • Inspect all equipment and dispose of expired medications and other supplies
  • Establish plan to transition procedures and billing to pre-COVID-19 standards
    • Check state governors’ orders, HHS updated policies, and OSHA guidance
•  Monitor your personal protective equipment (PPE) and medical supplies
  • Verify inventory of PPE / supplies, and estimate future needs, renegotiate contracts with vendors
  • Consider current PPE conservation, reuse, and sanitation measures and inform employees on use
    • Review the Food and Drug Administration FAQs on PPE, CDC PPE burn rate calculator
• Screen and monitor patients, employees, staff, and all third parties on-site
  • Consider ADA designation, state public health orders, and CDC guidance on screening for symptoms
  • Establish protocols for screening all persons, and document list of ill or symptomatic persons
  • Triage and quarantine patients accordingly, prior to and during patient visits with a symptom checklist
  • Limit third parties, declutter, and disinfect high traffic, common areas and high-touch surfaces
  • Adjust spacing in all facility areas, patient rooms, and waiting rooms to six feet, where possible
    • Equal Opportunity Employment Commission permitted screening, CMS reopening guidance
• Develop an interim phased-in work plan
  • Create tiered employee/staff scheduling for essential v. non-essential services
  • Consider continued use of telework flexibility going forward, even after social distancing is lifted
  • Consider available blanket waivers under CMS and further expanding services through telehealth
    • Main telehealth benefits include reduced COVID-19 exposure, cost-savings, time efficiency
    • Telehealth services are available in virtually any healthcare area so consider your workflow
    • See CMS non-emergent treatment recommendations, American Hospital Association guide
• Establish on-site health and safety guidelines
  • Set employee / staff social distancing and PPE recommendations, post health and safety signs
  • Evaluate use of common areas and limit persons in designated spaces
    • See CDC interim employer guidance, social distancing guidelines, healthcare personnel guide
• Create or update an emergency preparedness response plan
  • Utilize data and feedback for future emergencies and response actions, create backup personnel charts
  • Prepare secondary COVID-19 wave emergency plan, and circulate to employees/ staff
    • Review CDC pandemic preparedness response resources and planning information by setting
• Assess your financial integrity and leverage available resources
  • Evaluate and prioritize financial obligations, create contingency plan, utilize financial aids
  • Review insurance policies and consider any strategic adjustments or additions
    • See CARES Act Provider Relief Fund, CMS Accelerated payment program, and billing FAQs

The impact of the coronavirus on the healthcare industry remains unclear at this time; especially due to anticipated reoccurrences of COVID-19 outbreaks once business reemerges and social distancing restrictions are lifted. Therefore, healthcare entities should plan not only to return to providing care, but also plan for secondary influxes of COVID-19 cases. Finally, while the public health emergency has imposed new demands on healthcare providers, it also serves as a reminder to reassess business plans periodically and evaluate new opportunities for the delivery of care.