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COVID-19 Practice Management Issues

Managing supplies, testing, personnel, medico-legal concerns, and looking toward re-opening.

Updated 7/24/2020

  • The Secretary of HHS has renewed the Public Health Emergency (PHE) for another 90 days, thereby extending many of the flexibilities and waivers resulting from the declaration.
  • This collection of policies and procedures from the University of Washington offer some practical guidance that practices can use, especially related to triaging patients and conservation of PPEs.

Testing

ACP’s clinical guidance includes up-to-date information and resources on testing and treatment protocols, resources specific to PPEs, and much more. Like this toolkit, it is being updated regularly as new information is available. 

  • Access to testing is changing rapidly and varies by locality. Check with your local health department, hospital, reference labs, or state health authorities regarding access to testing. 
  • The CDC is the best resource for information regarding testing criteria and resources. As new testing becomes available, keep coming back for more information.

Practice Re-opening Resources

  • ACP’s Clinician’s Guide includes some resources to help guide practices in plans for re-opening.  Resources include guides, checklists, staffing and workflow modifications, and materials for communicating with patients.
  • The CDC offers a framework for providing non-COVID-19 care during the pandemic.
  • ACP offers clinical and public policy guidance on how to resume some economic, social and medical care activities to mitigate COVID-19 and allow expansion of healthcare capacity.

Staffing and Personnel

Due to illness, quarantine, or self-isolation, medical practices may be experiencing personnel shortages.  Below are some tips and considerations to mitigate these issues.

  • The Families First Coronavirus Relief Act included some requirements regarding paid leave for employees during the PHE. The Department of Labor has guidance on these temporary changes:
    • For employers: guidance regarding sick leave and extended family leave
    • This employee rights poster can be provided to employees electronically and/or posted in employee common areas.
  •  Have your staff call high-risk patients and check on them.  If they need to be seen, bring them into the office.  If they have COVID symptoms, consider “parking lot” visits.  
  • In order to minimize the number of patients in your waiting room and office, have the patients call when they have arrived.  If the office is ready for them they can come in and go directly to a room, or wait in their car until the staff member calls them back.  This allows staff to clean the exam rooms between patients and eliminate the need to use (and constantly disinfect) the waiting room.
  • For patients who are new to telehealth, have your staff call them prior to the appointment to do the history, confirm medication lists, and gather other information prior to the clinician appointment.  This gives a chance for the patient to “practice” using the technology (whatever that may be) before the physician conducts the actual visit.  
  • For check-in and check-out staff, you may need to get creative on solutions that create barriers or distancing between the patients and staff, using supplies such as plexiglass or sheets of plastic stretched across the opening, or set up a table in front of the desk to create more physical distance. 
  • The CDC offers guidance regarding personnel with exposure to patients with COVID-19. Practices should establish contact with state or local health departments about responsibilities of the practice vs the public health departments.

Supplies and Infection Control

We know that access to Personal Protective Equipment (PPE) has been a huge challenge.  Until supplies are able to catch up, below are some tips on where to find and how to conserve and/or maximize PPEs in your practice.

  • The CDC has more information on optimization of PPE. 
    • CDC offers guidance regarding the use of cloth face masks.
    • CDC guidance on regarding infection control, including patient placement, staff protection, and disinfection/cleaning.
  • Project N95 is a volunteer organization that serves as the national clearinghouse for personal protective equipment (PPE), including masks, gowns, gloves, face shields, goggles, respirators, and ventilators. Their mission is to deliver critical equipment into the hands of healthcare providers as quickly as possible.
  • Amazon has a new COVID-19 Business Group available to access supplies reserved for front line workers. Once you have set up a business account subscription and certified that you are a medical practice with your TIN and other information, supplies will become available. It takes 3-5 days to process applications.

Medico-Legal Considerations

  • It is important to contact your medical liability carrier regarding the current conditions in YOUR state because there is a good deal of variation regarding what immunity means during the COVID-19 public health emergency.  Some states are more “plaintiff friendly” than others so the flexibilities offered at the federal level may or may not apply to your state.
  • This 32-minute podcast by 2 medical malpractice attorneys discusses considerations about medical malpractice during the COVID 19 pandemic. Some states are adopting emergency measures that provide practitioners with additional protection, changing the standard for civil cases to 'gross negligence or willful misconduct'. But this does not mean the provider has blanket immunity from being sued at all. Lawsuits might still be filed that will need to be defended, even with this new standard (though likely fewer cases will be brought forth, because they will be much harder for plaintiffs to prevail). Because of the large costs associated with defending lawsuits, it is imperative that you are properly insured for however your practice changes in this pandemic. They also discuss considerations for retirees and volunteers, physicians who are changing the manner in which they see patients, and the importance of documenting circumstances in general.
  • Consent is still important.  Because cost sharing still applies in many cases, and because using telehealth is still new, it is important to seek and document verbal consent from the patient at the beginning of each remote visit. The Texas Medical Association includes many resources, but specifically has sample consent forms.