On June 9, 2020, CMS released recommendations for re-opening healthcare facilities to provide non-emergent, non-COVID-19 related health care. The guide is intended for use by states or regions in Phase II of re-opening under the Trump Administration’s Opening Up America Again Guidelines. Facilities are advised to check with state and local authorities to determine whether they are in Phase II before following the new CMS guidelines.

CMS recommends that healthcare systems and clinicians preserve capacity to handle potential surges of COVID-19 patients while simultaneously resuming non-emergent but clinically necessary care for non-COVID-19 patients. In pursuit of that goal, facilities are advised to:

• Evaluate the trend and incidence of COVID-19 in the area as well as health system capacity to ensure there is no evidence of a COVID-19 rebound;
• Evaluate the necessity of care based on clinical needs and prioritize service that will result in harm if deferred and at-risk populations who need services most;
• Establish non-COVID-19 care (NCC) zones where patients can be screened for COVID-19 symptoms, and continue routinely screening all staff;
• Maintain sufficient resources across all phases of care, including sufficient personal protective equipment (PPE), healthcare workers, facilities, supplies, and screening and testing capacity without jeopardizing the facilities’ surge capacity; and
• Participate in a data collection system, such as the National Healthcare Safety Network to help track patient outcomes, facility and system impacts, and resource allocation.

CMS advises facilities to continue to take steps to prevent the spread of COVID-19 to its in-person, non-emergent patients, including maintaining separate COVID-19 care zones in separate buildings, floors, or and/or rooms with minimal crossover of patients, staff, supplies, and personnel with non-COVID-19 patient areas. CMS states that controls should be established to facilitate social distancing, such as minimizing time in waiting areas, spacing chairs, and maintaining low volumes, and the number of visitors should be minimized.

Where possible, CMS advises that hospitalized patients and those undergoing a procedure should receive COVID-19 testing 24 hours prior to the procedure or admission. If testing is unavailable, patients should self-isolate for 14 days in advance of their procedure or hospitalization. If a patient tests positive for COVID-19 and clinical staff decide to proceed with care, care should be provided in a COVID-19 care zone. Clinical staff working in NCC zones should be screened daily upon arrival, and visitors showing symptoms or testing positive should be excluded from the NCC zones. Staff who will be working in NCC zones should not rotate into COVID-19 zones unless absolutely necessary. Staffing levels should remain adequate to cover a potential COVID-19 surge in the area.

CMS also recommends that healthcare providers and staff should wear surgical facemasks at all times unless an N95 respirator is required. Procedures with a higher risk of aerosol transmission should be done with caution and staff should utilize appropriate respiratory protection in the context of a comprehensive respiratory protection program compliant with the Occupational Safety and Health Administration (OSHA) Respiratory Protection Standard (29 C.F.R. § 1910.134). Patients and visitors should wear cloth face coverings, and facilities should be prepared to provide coverings or masks for patients and visitors who do not have one upon entry. Facilities should make every effort to conserve PPE, including by following CDC recommendations for extended use and reuse when necessary.

Finally, CMS’s guidelines include recommended sanitation protocols. Facilities are advised to establish a plan for thorough cleaning and disinfection prior to utilizing spaces for non-COVID-19 patients and to ensure that equipment used for COVID-19 positive patients are thoroughly decontaminated.

For higher risk patients, CMS advises clinicians to take the following CDC-recommended precautions, including:

• Developing a care plan with each patient and plan for how to receive urgent care should the need arise, including providing each patient with instructions for a 24/7 call-in line;
• Providing care remotely to the extent possible;
• Limiting major surgical procedures to the extent clinically possible; and
• Screening and providing facemasks to family members or caregivers.

The CMS recommendations are available here.