In Guidance issued May 8, 2020 and May 9, 2020, the Pennsylvania Department of Health (DOH) has now permitted medical and dental practices across the Commonwealth to re-engage in the provision of non-urgent or elective care, with certain limitations.
Medical practices may now resume non-urgent and elective care “only when appropriate personal protective equipment (PPE) is available and telemedicine is not clinically sufficient.” Each physician must “apply their clinical judgment, along with their knowledge of the incidences of COVID-19 cases in their area, the needs of their patients and staff, and the availability of any necessary supplies” in assessing whether to resume the provision of non-urgent or elective care. (See DOH Medical Practice Guidance).
Similarly, dental practices may resume non-urgent and elective care only with use of proper PPE, and should use teledentistry whenever possible. Like physicians, each dentist must also apply “their clinical judgment, along with their knowledge of the incidences of COVID-19 cases in their area, the needs of their patients and staff, and the availability of any necessary supplies” in assessing whether to resume such care. However, dentists may not perform aerosolizing procedures, such as those that create a visible spray that contains “large particle droplets of water,” except as a last resort when clinically necessary and proper PPE, per OSHA guidance, is used for all dental care practitioners (including hygienists). (See DOH Dental Practice Guidance). A DOH spokesperson commented that this Guidance does not permit routine cleanings (likely due to the prohibition on aerosolizing procedures), but does permit procedures like orthodontic work and root canals. (See this article).
All patients (whether medical or dental) should be screened for symptoms of COVID-19 (including a temperature over 100.4 degrees Fahrenheit, cough or shortness of breath), such as by use of a questionnaire or “other acceptable method,” before arriving at the practice. Fox Rothschild has developed Patient Notice and Acknowledgement Forms for use in complying with this requirement, as further discussed in our recent Alert.
In addition, the following precautions must be implemented:
- social distancing must be maintained while in the office, per CDC guidelines;
- patients must wash or sanitize hands frequently; and
- patients must wear masks.
Staff should wear appropriate PPE in accordance with guidance from OSHA (link here) and the CDC Infection Prevention and Control Guidance (link for CDC Dental Guidance | link for CDC Medical Guidance).
Note that the CDC Guidance recommends actively screening all patients and staff for fever and symptoms of COVID-19 before entering the practice. Also, physical barriers (e.g., glass or plastic ) should be installed at reception areas.
Note also the newly released OSHA Guidance for Dental Practices, which recommends installation of physical barriers between patient treatment areas.
Generally speaking, medical and dental practices should pre-screen patients for COVID-19 symptoms and exposure, and reschedule appointments when appropriate. Dental practices remain prohibited from performing any procedures on patients suspected or confirmed to have COVID-19, except in a facility having a negative pressure room with use of enhanced PPE. (See DOH Dental Guidance).
Resuming operations should also involve the implementation of appropriate employee policies regarding COVID-19, and frequent sanitization in accordance with CDC and DOH guidance.
If you have any questions regarding the re-opening of your practice, the updating of policies or the use of new forms, please do not hesitate to contact us.