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Responding To The Coronavirus

By | Compliance, COVID-19 | No Comments

Although the CDC has released new safety guidelines for individuals who have been fully vaccinated, doctors offices should note that the recent changes do not apply to healthcare personnel while at work and all patients while they are being cared for in a healthcare setting.

With some states reopening and COVID mandates being lifted, what are the latest CDC requirements for keeping patients and staff safe while in your office setting?

Masking Protocols:

Some patients refuse to wear masks and may not understand that the CDC’s lifting of masking protocols for fully vaccinated patients does not apply to healthcare settings.

Thus, when making appointments for in-office visits, practice staff should continue to set office expectations prior to coming into the office regarding established infection control protocol set by the CDC.

Additionally, a sign posted on the front door and in the reception area will help to alert patients that the masking protocols are still in effect.

If a patient is uncooperative upon arrival, healthcare providers should ask the patient to step aside to a private area where are you can address the patient’s concerns.

If the patient gets angry, let them know that you are obligated to follow guidelines set forth by the CDC as well as other government agencies, to ensure everyone’s safety.

If the patient becomes hostile or uncooperative, you always have the right to suggest that the patient seek care elsewhere. But remember, that if you decide to terminate the doctor patient relationship over this issue, it is critical that you end the relationship in a manner that will not lead to claims of discrimination or patient abandonment.

Social Distancing:

The CDC still recommends physical distancing within your facility and requires that patients sit at least six feet or more apart. If it is practical, you could ask patients to wait in their car and text them when you’re ready to see them.

Ask anyone accompanying the patient to wait in the car during the appointment if possible.

Do not allow staff members who are sick, have been sick or have sick family members to come to the office.

Environmental Infection Control Protocol:

  • Routinely clean and disinfect frequently touched surfaces, treatment tables or objects. Cleaning guidelines vary based on devices and surfaces being cleaned.
  • Remove magazines and toys from the waiting room.
  • Routinely disinfect the waiting room and bathrooms throughout the day.
  • Develop a cleaning schedule and checklist for your facility, and document compliance in your administrative files that the cleaning schedule is followed.
  • Provide approved face masks to patients and all caregivers and staff to use.
  • Have alcohol-based hand rub available in the reception area, waiting room, patient care and restroom areas.

Patient Screening Protocol:

Screen patients calling to schedule an appointment by asking them:

  1. If they or anyone in their family has a fever or has had one in the last two weeks.
  2. Have they or family members had any symptoms of a cold or flu?
  3. Have they traveled abroad in the last two weeks?
  4. Have they been near anyone who has potentially had the virus through their
    family or work?

For individuals entering your facility, query all patients about symptoms of coronavirus, whether in written form or verbally by your staff, take their temperature, and then document findings in the soap note on each visit.

For example:

  • “The patient was questioned with regards to recent travel and exposure to illness including COVID-19.
  • The patient denies any close contact with individuals who have confirmed cases of coronavirus and recent travel to high-risk areas within the last 14 days.
  • The patient denies the following symptoms: fever or chills, cough, shortness of breath,
    fatigue, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea or vomiting or diarrhea.
  • Temp: 98.6″

Office Preparedness Protocol:

  • Design a COVID-19 office management plan.
  • Educate staff about coronavirus and why it is important to contain the outbreak.
  • Educate staff on facility policies and practices to minimize chance of exposure.
  • Train staff on how to advise patients about changes in office procedures (e.g., calling prior to arrival if the patient has any signs of a respiratory infection and taking appropriate preventive actions.
  • Prepare for office staff illness, absences, and/or quarantine by cross-training staff for all essential office and patient care functions.
  • Implement mechanisms and policies that promptly alert key facility staff about known suspected COVID-19 patients.
  • Keep updated lists of staff and patients to identify those at risk in the event of an exposure.


OSHA released its new Emergency Temporary Standard (ETS) for COVID on June 10, 2021, with an effective date of June 15. Impacted healthcare employers are expected to comply with most requirements within 14 days of publication and within 30 days for the remainder of the requirements (e.g., employee training).

OSHA’s COVID-19 Healthcare Emergency Temporary Standard (ETS),29 CFR 1910.502 paragraph (c), requires employers to develop and implement a COVID-19 plan for each workplace to protect workers from COVID-19.

Additionally, if an employer has more than 10 employees, the plan must be written.

Fortunately, most offices will not be affected by OSHA’s COVID-19 Healthcare ETS requirements.

To determine if the new mandate applies to your workplace or portions of your workplace, answer the following questions.

  1. Is the workplace a setting where any employee provides healthcare services or healthcare support services?
  2. Does the workplace meet all the following conditions?
  3. It is a non-hospital ambulatory care setting?
  4. Are all non-employees are screened prior to entry?
  5. People with suspected or confirmed COVID-19 are not permitted to enter?

If you answered yes to all of the above than the ETS does not apply to your workplace?

In conclusion, make sure that both staff and patients are aware of your offices policies regarding the SARS-CoV-2 virus.

1. Advise them of the precautions you are taking to provide a safe workplace and give them the opportunity to voice any concerns.

2. Document your compliance with the CDC protocols and employee training on COVID office policies and procedures.

3. Develop a cleaning schedule and checklist for your facility, and document compliance with CDC requirements that the cleaning schedule is followed.

4. Make sure that your office staff is following patient screening protocol and document patient screening procedures in your S.O.A.P notes.

Remember that the Occupational Safety and Health Act (“OSHA”) requires employers to provide employees with a workplace free from recognized hazards that are causing or are likely to cause death or serious physical harm.

Failure to comply with applicable laws, including reporting and investigative demands, is grounds for revoking not only your license to practice but also your office’s operating license.

If you have any questions, don’t hesitate contacting Compliance & Auditing Services.