What liability does our organization face as it relates to our staff by keeping our practice open for patients during this time?

The liability comes if you are not providing employees with what they need to safely provide care while following CDC and OSHA guidelines for managing potentially infectious patients.

This includes providing PPE for appropriate use, applying infection control measures, and implementing a plan to mitigate risk of exposures. Read more on the OSHA 2019 Novel Coronavirus website.

Here are some actions practice leaders should take:

• Stay in proactive communication with your practices/staff and address questions, concerns, or needs they have. Make sure contingency plans have been implemented and employees are trained on what to do, including how to properly use PPE. Contingency plans should include risk mitigation strategies, such as screening patients prior to arriving for an appointment and educating employees on what to do if they have a positive screen.
• Refer to our COVID-19 Patient Workflow Chart for guidance on managing potentially infected patients in your practice.
• Implement source control for everyone entering a healthcare facility (e.g., healthcare personnel, patients, visitors), regardless of symptoms, to address asymptomatic and pre-symptomatic transmission.
  • This action is recommended to help prevent transmission from infected individuals who may or may not have symptoms of COVID-19.
  • Cloth face coverings are not considered PPE, because their capability to protect healthcare personnel (HCP) is unknown. Face masks, if available, should be reserved for HCP.
  • For visitors and patients, a cloth face covering may be appropriate. If a visitor or patient arrives to the healthcare facility without a cloth face covering, a facemask may be used for source control if supplies are available.
• Actively screen everyone for fever and symptoms of COVID-19 before they enter the healthcare facility.
• As community transmission intensifies within a region, healthcare facilities could consider foregoing contact tracing for exposures in a healthcare setting in favor of universal source control for HCP and screening for fever and symptoms before every shift.

Here are links to additional guidance for:

• • Infection Prevention and Control Recommendations for Patients with Suspected or Confirmed COVID-19
  • Strategies to Optimize the Supply of PPE and Other Equipment
  • Interim Guidance for Discontinuation of Transmission-Based Precautions and Disposition of Hospitalized Patients with COVID-19
  • Interim Guidance on Criteria for Return-to-Work for Healthcare Personnel with Confirmed or Suspected COVID-19
  • Strategies to Mitigate Staffing Shortages

Of note: Don’t forget while evaluating patients for risk factors related to coronavirus, practices need to also remember to address the other medical needs of the patient, asking:

• Is this patient scheduled for a non-essential visit that can be rescheduled for later?
• Are there unresolved issues that need addressing?
• Can these unresolved issues be handled via telehealth or does it require an in-person visit?