On April 16, 2020, Federal guidelines were introduced for “Opening up American Again”. Those guidelines included gating criteria for healthcare facilities to follow for commencing non-COVID care. Please note that continued adherence to State and Federal guidance on hand hygiene, use of face masks, disinfection practices, and social distancing, regardless of the Phase entered, should continue. Additionally, as healthcare providers, strict policies on visitation, screening, use of PPE, and disinfection within facilities must continue during this current pandemic.  Relaxing the use of strict hand hygiene practices, visitation, social distancing, and workforce and visitor screening will open up healthcare facilities to a possible return to crisis care, placing the entire patient population at risk.

Before considering any resumption of services under Phase One, the following Federal gating criteria must be met by the States.  The gating criteria includes the symptoms of the patient population, the decrease of COVID-testing and cases, and the ability to test and treat patients. Federal guidance requires the following gating criteria be met before moving forward into Phase One:


Source:  Guidelines, Opening Up America Again, April 16, 2020.

Phase One

Under Federal guidelines, when the above gating criteria are met, organizations can move into Phase One.  Please note, however, that while some States have adopted the Federal gating criteria, others have issued Executive Orders or State Plans which guide that particular State’s activities.  Each healthcare facility must understand what  the requirements are per each individual State.   

Phase One permits the resumption of outpatient elective surgeries with strict adherence to CMS guidelines.  As such, careful planning must take place to ensure hospitals and ASCs have anticipated all necessary steps. A well thought out and written plan to mitigate risk must be in place, to the extent possible, prior to implementation.

A well written plan should include the following:

  • Pre-operative Screening and Testing of Patients;
  • Infection Prevention Practices;
  • Personal Protective Equipment Use and Availability;
  • Physical Separation for Non-COVID Care;
  • Cleaning and Disinfection;
  • Scheduling Staff for Non-COVID Care Only;
  • Staff Screening and Testing;
  • Reporting Responsibilities;
  • Social Distancing for Necessary Support System and Screening Procedures; and
  • Staff Training and Education.

While many facilities will be anxious to resume elective procedures as quickly as possible, careful consideration must be given to the safety of patients and staff alike.  The written plan should be developed and adopted internally prior to implementation. Prior to resuming outpatient elective procedures, Advis recommends that contact be made with your organization’s State Department of Health to receive written approval to move forward.

Advis continues to stay at the forefront of regulatory and reimbursement issues stemming from the COVID-19 crisis. Advis stands ready to assist your organization in the development and implementation of a written plan for reopening non-COVID care.  Advis is also available to address questions regarding your State’s requirements and how they may differ from Federal guidelines.  Please contact our office at 708-478-7030 for assistance in resuming outpatient elective surgeries during the current pandemic.

Published: May 14, 2020