News & Media

Michigan Executive Orders and Impact on Medical Practices

Thursday, May 28, 2020

Updated May 26, 2020

Michigan Executive Orders issued in response to COVID-19 impact Michigan medical practices as providers of medical services and as employers.  The goals of the Executive Orders are to mitigate the spread of COVID-19 and to protect Michigan’s citizens, health care system and other critical infrastructure.  Willful violations of the Executive Orders are misdemeanors.

On May 22, 2020, Governor Whitmer issued Executive Order 2020-99 which, for a second time since April 30, 2020, re-declared a state of emergency and state of disaster in the State of Michigan through June 19, 2020 at 11:59 p.m. The Executive Order confirms that all previously issued Executive Orders under the original states of emergency and disaster will continue in effect under the re-declared states of emergency and disaster.  On May 22, 2020, the Governor also issued Executive Order 2020-100 which extends the stay-at-home order through June 12, 2020 at 11:59 p.m.  However, as noted below, medical practices are permitted to resume furnishing non-essential procedures on May 29, 2020, subject to compliance with applicable Executive Orders which continue until they expire, are rescinded or are declared unenforceable by competent legal authority.

On May 6, 2020, in response to Governor Whitmer’s initial re-declaration of a state of emergency and state of disaster in the State of Michigan, the Michigan legislature filed a lawsuit challenging the Governor’s authority to extend or re-declare a state of emergency and state of disaster without the legislature’s approval. On May 21, 2020, the Michigan Court of Claims issued an opinion and order which upheld the Governor’s authority to extend a state of emergency under one of two applicable laws at issue, although the court’s decision has been appealed to the Michigan Supreme Court. Notwithstanding, it is the Governor’s position that the states of emergency and disaster, and all Executive Orders issued thereunder, are legally enforceable. Therefore, it is advisable for medical practices and physicians to continue to comply with all applicable Executive Orders unless and until the Executive Orders expire, are rescinded or are declared unenforceable by competent legal authority.

Through May 26, 2020, the Governor has issued 98 Executive Orders related to the COVID-19 pandemic.  Executive Orders which affect medical practices include 2020-17, 2020-61, 2020-64, 2020-72, 2020-86, 2020-96 and 2020-97.  Other Executive Orders omitted from this publication, including Executive Order 2020-36 (protecting workers who stay home, stay safe when they or their close contacts are sick), affect employers generally, including medical practices.  In addition, some county and local governments have issued their own emergency orders.

The following are key points for physicians and medical practices:

  • Until May 28, 2020 at 11:59 p.m., medical practices should limit their in-person patient visits to essential services and those not subject to postponement under Executive Order 2020-17.   Executive Order 2020-17 is rescinded beginning at 12:00 a.m. on May 29, 2020, which means that medical practices and other health care providers are not prohibited by Executive Order from furnishing non-essential procedures.
  • Through May 28, 2020 and thereafter while applicable Executive Orders remain in effect:
    • Staffing must be limited to necessary clinical and non-clinical staff.
    • The requirements of Executive Orders 2020-17, 2020-61, 2020-64, 2020-72, 2020-86, 2020-96 and 2020-97 must continue to be followed unless and until they are rescinded, expired, or otherwise declared unenforceable.
    • If patient encounters do not require in-person visits, physicians can consider telemedicine encounters.
    • Physician medical practices are permitted to conduct minimum basic operations which require designated workers to be present in-person at the office, subject to the requirements of Executive Orders 2020-96 and 2020-97. All other workers who can work remotely would need to do so if authorized by the practice to do so.
    • Adhere to the Centers for Disease Control and Prevention (CDC) recommendations for infection prevention and control.
    • Check with national specialty associations for further guidance on nonessential versus essential encounters.

Executive Order 2020-17

This Executive Order 2020-17, issued on March 20, 2020, imposes temporary restrictions on non-essential medical and dental procedures.  Pursuant to Executive Order 2020-96, it continues in effect until May 28, 2020 at 11:59 p.m., after which the Executive Order is rescinded.  Executive Order 2020-17 requires all covered facilities (hospitals, freestanding surgical outpatient facilities, dental facilities, and all state-operated outpatient facilities) to implement a plan to temporarily postpone all non-essential procedures. A “non-essential procedure” is defined as “a medical or dental procedure that is not necessary to address a medical emergency or to preserve the health and safety of a patient, as determined by a licensed medical provider.”

Additionally, the covered facilities noted above and medical centers or offices that perform elective surgeries or cosmetic plastic surgeries are required to minimally postpone joint replacement, bariatric surgery, and cosmetic surgery. Exceptions can be made for emergency or trauma-related surgery where postponement would significantly impact the health, safety, and welfare of the patient. A plan for a covered facility that performs medical procedures should exclude from postponement: surgeries related to advanced cardiovascular disease (including coronary artery disease, heart failure, and arrhythmias) that would prolong life; oncological testing, treatment, and related procedures; pregnancy-related visits and procedures; labor and delivery; organ transplantation; and procedures related to dialysis.

On May 3, 2020, Michigan’s Chief Medical Executive, Joneigh Khaldun, MD, MPH, FACEP, sent a letter to Michigan clinicians providing further guidance related to Executive Order 2020-17, including what is allowable under the Executive Order, how to start to re-engage with patient for important care, and determining the timeliness and necessity of care for individual patients. Dr. Khaldun stated that Executive Order 2020-17 is “intended to be flexible, preserve clinician judgment, and encourage consideration on an individual basis of which patient services can be safely delayed without resulting in significant decline in health. [Executive Order] 2020-17 gives providers broad discretion to apply this standard.”

Although this Executive Order does not explicitly state that it applies to physician medical practices and clinics, it should be treated as applicable to them, given its broad scope and the State’s position that Executive Order 2020-72 applies to medical practices. Even after the  rescission of Executive Order 2020-17 is effective, physician medical practices, urgent care centers and clinics may still wish to consider whether non-urgent procedures should be rescheduled or, if appropriate, switched from in-person to telemedicine, and/or if any additional precautions may be appropriate to protect patients and health care staff.  Physicians may want to check whether their national specialty societies have issued recommendations on such matters.

Executive Order 2020-61

 

This Executive Order, issued on April 26, 2020, provides temporary relief from certain restrictions and requirements governing the provisions of medical services in support of the response to the COVID-19 pandemic. This Executive Order supersedes Executive Order 2020-30, which was issued on March 29, 2020 and has been rescinded. It continues in effect for the duration of the state of emergency and state of disaster re-declared and now governed by Executive Order 2020-99 issued on May 22, 2020, or the end of any subsequently declared states of disaster or emergency arising out of the COVID-19 pandemic, whichever comes later. 

 

Executive Order 2020-61 temporarily suspends laws under Article 15 of the Public Health Code relating to scope of practice, supervision and delegation  to the extent necessary to allow licensed, registered or certified health care professionals, as well as certain medical and other health care professional students, and qualified volunteers or personnel, to provide medical or other services within a “designated health facility” that are necessary to support the facility’s response to the COVID-19 pandemic and are appropriate to the professional, student or volunteer’s education, training and experience as determined by the facility in consultation with the facility’s medical leadership. In addition, the Executive Order clarifies that medical services provided in accordance with the Executive Order will not be subject to criminal, civil or administrative penalty related to a lack of physician supervision or the lack of a written practice agreement with a licensed physician.

 

The Executive Order defines “designated health facility” as hospitals, freestanding surgical outpatient facilities, nursing homes, and other facilities which qualify as “health facilities” under MCL §333.20106(1), state-owned surgical centers, state-operated outpatient or veteran facilities, and entities used as surge capacity by any of the foregoing facilities.

 

The Executive Order permits health care professionals that are licensed and in good standing in another state to practice their profession in Michigan without criminal, civil or administrative penalty related to lack of licensure. The Executive Order also confirms that unlicensed physicians, such as physicians who have retired and allowed their medical license to lapse within 5 years or less, may provide medical services to COVID-19 patients or other services in support of the COVID-19 pandemic without a license in accordance with MCL §333.16171. In addition, the Executive Order temporarily suspends the licensing requirements of parts 170, 172, 175 and 187 of the Public Health Code to the extent necessarily to allow the Michigan Department of Licensing and Regulatory Affairs to issue a license that lasts for the duration of the declared states of emergency and disaster to any physician, physician’s assistant, registered professional nurse, licensed practical nurse or respiratory therapist who meets certain qualifications including (1) is licensed in good standing in another country, (2) has at least five years’ practice experience, (3) has practiced for at least one year in the last five years, and (4) substantially meetings the requirements for licensure of the Public Health Code by education, training or experience.

 

To address concerns of professional liability and other liability exposure related to volunteering or otherwise provided services in support of the response to the COVID-19 pandemic, the Executive Order provides a number of immunity and other protections, including the following:

  • Licensed or unlicensed health care professionals (including retired physicians and medical students) who provide medical or other services to COVID-19 patients, or otherwise in support of the state’s response to the COVID-19 pandemic are not liable for malpractice or other injury claims absent gross negligence.
  • Services provided by unlicensed volunteers or students at a designated health care facility are entitled to the same rights and immunities provided to state employees under MCL §30.411(1)(c).
  • Temporary suspension of laws and regulations relating to examination, fingerprinting and continuing medical education requirements as a condition of licensure, certification, registration or the renewal of a license, certification or registration of health professionals. Clarification will be needed as to whether this temporary suspension applies only if licensure or renewal of licensure is sought during the emergency declaration, or if leniency will be offered to licensees regarding these requirements during the next renewal cycle.
  • Temporary suspension of laws and regulations relating to fingerprinting as a condition of licensure and certification for hospitals, nursing homes, county medical care facilities, or psychiatric hospitals.
  • Extension of professional certifications in basic life support, advanced cardiac life support, or first aid throughout the duration of the emergency declaration, even if they are otherwise set to expire during the emergency.

Executive Order 2020-64

This Executive Order was issued on April 29, 2020 and affirms certain anti-discrimination policies and procedures to ensure the equitable allocation of medical resources. It continues in effect for the duration of the state of emergency and state of disaster re-declared now governed by Executive Order 2020-99 issued on May 22, 2020, or the end of any subsequently declared states of disaster or emergency arising out of the COVID-19 pandemic, whichever comes later.

Executive Order 2020-64 confirms the State of Michigan’s public policy that no person should be denied medical care on the basis of stereotypes, assessments of quality of life, or judgments about a person’s relative “worth,” including, judgments about a person’s worth based on the presence or absence of disabilities. The Executive Order requires health care providers to do both of the following:

  • Take all necessary steps to ensure non-discrimination in the delivery of critical care and allocation of other medical resources to those in need of treatment for physical and psychiatric illnesses, including non-discrimination based on social stigma or stereotypes regarding age, color, criminal history, disability, ethnicity, familial status, gender identity, height, homelessness, immigration status, incarceration status, marital status, mental illness, national origin, poverty, race, religion, sex, sexual orientation, socio-economic status, substance abuse disorder, use of government resources, veteran status, or weight (collectively, the “Non-Discrimination Characteristics”).
  • Continue to support individuals’ functional needs to the fullest extent possible. The Executive Order defines “functional needs” to include the needs for independence, communication, transportation, supervision, and medical care. The Executive Order states that when effective communication requires that a sign language interpreter be present, a sign language interpreter must be permitted to be present and provided with appropriate PPE.

Importantly, the Executive Order does not appear to define or limit who qualifies as a health care provider within the meaning of the Executive Order. Accordingly, if and until such clarity is provided, all health care providers should comply with the above provisions of this Executive Order.

The Executive Order further requires “designated health care facilities” to develop protocols that guide decision-making for medical care in cases where demand for critical medical resources exceeds availability during the COVID-19 pandemic. Such protocols must do each of the following:

  • Enable clinical decision-making based on the best available objective medical evidence, including and individualized assessment of how each patient will respond to treatment.
  • Prohibit medical decision-making based on the Non-Discrimination Characteristics.
  • Provide for coordinating and sharing information with the Michigan Department of Health and Human Services (MDHHS) regarding resource availability and transfer ability.
  • Ensure that withholding or delaying care due to lack of critical resources is always a last resort.
  • Require the protocols to be available upon request, and whenever the protocols are in effect, posted on the internet.

For purposes of this Executive Order, the term “designated health care facility” is limited to a hospital or an entity used as surge capacity by one or more hospitals.

Executive Order 2020-72

This Executive Order, issued on May 3, 2020, imposes limited and temporary restrictions on the entry of individuals into health care facilities, residential care facilities, congregate care facilities, and juvenile justice facilities through Sunday, May 31, 2020 at 11:59 pm. This Executive Order supersedes Executive Order 2020-37, which was issued on April 5, 2020, which superseded Executive Order 2020-7 issued on March 14, 2020.  Previously, the Michigan Department of Health and Human Services confirmed that “any place that offers health care services is considered a health care facility and is subject to Executive Order 2020-07.”  This includes physician-owned and operated medical practices.  See Executive Order 2020-37 questions and answers, which are presumed to apply to Executive Order 2020-72.

Under Executive Order 2020-72, the following persons are prohibited from entering the above-mentioned facilities including medical practices:

  • Persons who are not necessary for the provision of medical care, the support of activities of daily living, or the exercise of power of attorney or court-appointed guardianship for an individual under the facility’s care;
  • Persons who are not a parent, foster parent, or guardian of an individual who is 21 years of age or under and who is under the facility’s care;
  • Persons who are not visiting an individual under the facility’s care that is in serious or critical condition or in hospice care; and
  • Persons who are not visiting under exigent circumstances or for the purpose of performing official governmental functions.

The Executive Order requires all health care facilities, including medical practices, to screen all individuals each time before they enter the facility. This applies to all permitted visitors and clinical and non-clinical staff. These individuals must be evaluated for symptoms of a respiratory infection, such as fever, cough, shortness of breath, or sore throat, and contact in the last 14 days with someone with a confirmed diagnosis of COVID-19. If an individual does not meet such screening criteria, he or she cannot enter the practice.

The State has addressed the meaning of “contact” for the purposes of health care workers who are treating COVID-19 patients as follows:

“Contact for the purposes of health care exposures is defined as follows: a) being within approximately 6 feet (2 meters), of a person with COVID-19 for a prolonged period of time (such as caring for or visiting the patient; or sitting within 6 feet of the patient in a healthcare waiting area or room); or b) having unprotected direct contact with infectious secretions or excretions of the patient (e.g., being coughed on, touching used tissues with a bare hand).”

See questions and answers on Executive Order 2020-37.

The Executive Order does not address the evaluation of patients seeking to enter a medical practice or other health care facility for treatment and services. 

Before and following the expiration of Executive Order 2020-72, it is recommended that all medical practices adhere to the Centers for Disease Control and Prevention (CDC) recommendations for infection prevention and control which include patient screening protocols. The CDC handout, Get Your Clinic Ready for Coronavirus Disease 2019 (COVID-19), offers step-by-step guidance on how to proceed.  CMS has also provided additional guidance for medical practices re-opening and resuming non-emergent, non-COVID-19 healthcare, including the screening of patients.

Executive Order 2020-86

This Executive Order was issued on May 14, 2020 to further enable the use of telehealth services and encourage the expansion of telehealth services through other means. It continues in effect during any state of emergency or state of disaster arising out of the COVID-19 pandemic, including the states of emergency and disaster declared under Executive Order 2020-99 issued on May 22, 2020.

To facilitate the provision of telehealth services, the Executive Order provides the following:

  • All health care providers are authorized and encouraged to use telehealth services when medically appropriate and upon obtaining patient consent. Patient consent is not required to be obtained in writing, but may instead be obtained verbally provided that such verbal consent is documented in the patient’s file before providing telehealth services.
  • In addition to or in combination with interactive, real-time, two-way audio technology, health care providers engaging in telehealth services may use “asynchronous store-and-forward technology” to enable the transmission of medical information to be reviewed at a later time by a health care provider.  Health care providers may also use “remote patient monitoring” technology as an available telehealth service. “Remote patient monitoring” means digital technology to collect medical and other forms of health data from an individual in 1 location and electronically transmit that information via a HIPAA-compliant, secure system to a health care provider in a different location for assessment and recommendations. Remote patient monitoring also includes observation, education, and virtual visits, including by home health care providers.
  • A physician is not required to conduct an in-person examination before prescribing medication or ordering the administration of medication, including controlled substances except for methadone. Although Michigan law does not generally require an in-person examination before prescribing controlled substances, the Executive Order is consistent with federal Drug Enforcement Agency (DEA) guidance that has confirmed the in-person examination requirement before prescribing controlled substances under the federal Controlled Substances Act does not apply during a public health emergency. In addition to existing Michigan law regarding the prescribing of controlled substances, physicians can refer to additional guidance issued by the DEA for prescribing controlled substances to patients during the COVID-19 public health emergency.
  • Strict compliance with MCL §500.3476 regarding the provision of telemedicine services is suspended only to the extent necessary to effectuate the above provisions. In addition, the Executive Order temporarily suspends MCL §500.3476 to the extent necessary to allow a medical professional licensed  and in good standing to practice in a state other than Michigan to use telehealth when treating patients in Michigan without a license to practice medicine in Michigan.

To facilitate the reimbursement of telehealth services, the Executive Order authorizes and encourages Healthy Michigan and private insurance carriers to reimburse for telehealth services. The Executive Order requires insurance carriers to cover virtual check-ins and e-visits. In addition, insurance carriers are prohibited from imposing additional requirements inconsistent with guidance issued by CMS on March 17, 2020. The Executive Order further states that telehealth services are covered under the Michigan Medicare/Medicaid Assistance Program and Healthy Michigan Plan if the originating site is an in-home setting or any other originating site allowed in the Medicaid Provider Manual or considered appropriate by the provider.

The Executive Order also provides additional clarifications and relaxation of certain laws and administrative rules to encourage the provision of telehealth services, including the following:

  • Healthcare providers must still abide by applicable guidance issued by the Substance Abuse and Mental Health Services Administration (SAMSHA), CMS, the CDC, and the DEA when providing telehealth services. The Executive Order temporarily suspends strict compliance with administrative rules that apply to substance use disorder services programs to the extent necessary to abide by the aforementioned guidance.
  • A controlled substance license issued under part 73 of the Public Health Code is sufficient to authorize a licensee to prescribe, administer, or dispense a controlled substance to treat a drug-dependent person enrolled in a drug treatment and rehabilitation program, regardless of whether the program is in-patient, out-patient, office-based, or another format. The Executive Order temporarily suspends Article 7 of the Public Health Code and certain administrative rules promulgated thereunder to the extent necessary to effectuate the aforementioned provision.
  • If a health care provider determines that an in-person evaluation, examination or visitation is not feasible due to the COVID-19 pandemic, the health care provider may use two-way interactive video technology or other remote participation tools to satisfy the requirement of an in-person evaluation, examination, or visitation under Article 5, part 3 of the Estates and Protected Individuals Code, and Chapters 4, 4A, 5 and 10 of the Mental Health Code. In addition, the Executive Order temporarily suspends strict compliance with certain sections of the Michigan Medical Marihuana Act to allow relevant medical evaluations to be conducted via telemedicine. 

Executive Order 2020-96

This Executive Order was issued on May 21, 2020.  Due to Executive Order 2020-100 issued on May 22, 2020, it requires Michigan residents to stay in their places of residence to the maximum extent feasible through June 12, 2020 at 11:59 p.m.  Executive Order 2020-96 supersedes Executive Order 2020-91 issued on May 18, 2020, Executive Order 2020-77 issued on May 1, 2020, as well as similar Executive Orders, including Executive Order 2020-59 issued on April 24, 2020, Executive Order 2020-42 issued on April 9, 2020, and Executive Order 2020-21 issued on March 23, 2020, each of which have been rescinded.

Under the Executive Order, only persons whose jobs are necessary to sustain or protect life, to conduct minimum basic operations, or to perform resumed activities may leave their residences to go to work at the employer’s premises.  Only businesses and operations that employ critical infrastructure workers or workers who perform resumed activities may continue in-person operations, subject to certain conditions. Clinical health care workers are included as critical infrastructure workers (“necessary to sustain or protect life”). If a medical practice chooses to remain open, the medical practice must determine which clinical health care workers are to continue to report to work, and whether any non-clinical staff is required to work on site to strictly conduct minimum basic operations, which are limited to the performance of functions such as processing transactions (e.g., payroll, employee benefits, etc.), security (e.g., the reception counter, etc.), or to facilitate the ability of other workers to work remotely. If such non-clinical staff is necessary, they must be so designated by the medical practice.  These designations must be confirmed in writing. A designation can be written on paper or in an email and should identify the employee by name and the basis for the designation (e.g., processing transactions). It is not necessary for workers to carry copies of their designations when they leave home for work, but it is advisable to do so.  Clinical staff do not need to be designated as critical infrastructure workers, but it may be helpful for medical practices to confirm their status in writing if they do not have hospital-issued or similar identification cards.  Medical practices generally do not employ workers who perform resumed activities, which are defined as tasks such as processing remote orders for delivery or curbside pickup, landscaping, moving and storage operations, and other non-medical tasks.    

Executive Order 2020-96 also requires that:

  • Medical practices and other businesses and operations maintaining in-person activities must adopt social distancing practices and other mitigation measures to protect workers and patrons as set forth in Executive Order 2020-97 (described below) and any orders that may follow from it.
  • Any individual able to medically tolerate a face covering must wear a covering over his or her nose and mouth—such as a homemade mask, scarf, bandana, or handkerchief—when in any enclosed public space, such as a medical office or facility. 
  • Medical practices whose workers perform in-person work must, at a minimum, provide non-medical grade face coverings to their non-health care professional workers and N95 masks or surgical masks to their healthcare professional workers.
  • The protections against discrimination in the Elliott-Larsen Civil Rights Act, 1976 PA 453, as amended, MCL 37.2101 et seq., and any other protections against discrimination in Michigan law, apply in full force to persons who wear a mask under this order.

Through May 28, 2020, medical practices that remain open should limit their in-person patient encounters to those essential to maintaining the life and health of patients, including those encounters not subject to postponement under Executive Order 2020-17. The Executive Order rescinds Executive Order 2020-17 as of May 28, 2020 at 11:59 p.m. Additionally, medical practices should consider whether medical visits can be conducted via telemedicine. Medical practices that remain open for in-person appointments, before and after May 28, 2020, must comply with visitor restrictions and screening requirements pursuant to Executive Order 2020-72 while in effect, as well as adopt social distancing practices and other mitigation measures which include, but are not limited to:

  • Developing a COVID-19 preparedness and response plan, consistent with recommendations in Guidance on Preparing Workplaces for COVID-19, developed by the Occupational Health and Safety Administration and available here.
  • Such plan must be available at the office.  
  • Restricting the number of workers present on premises to no more than is strictly necessary to perform minimum basic operations and critical infrastructure functions.
  • Promoting remote work to the fullest extent possible.
  • Keeping staff and patients on premises at least six feet from one another to the maximum extent possible.
  • Increasing standards of facility cleaning and disinfection to limit worker and patient exposure to COVID-19, as well as adopting protocols to clean and disinfect in the event of a positive COVID-19 case in the workplace.
  • Adopting policies to prevent workers from entering the premises if they display respiratory symptoms or have had contact with a person with a confirmed diagnosis of COVID-19.
  • Any other social distancing practices and mitigation measures recommended by the Centers for Disease Control.

The Executive Order also created eight separate geographic regions for the State of Michigan, each of which consist of certain specified counties. For example, Region 1 includes Monroe, Washtenaw, Livingston, Genesee, Lapeer, Saint Clair, Oakland, Macomb and Wayne counties. The Executive Order includes certain provisions which apply only to certain specified regions.

Executive Order 2020-97

This Executive Order was issued on May 21, 2020 and sets forth certain workplace standards to apply to all businesses across the state, including new provisions governing outpatient health care facilities. The Executive Order supersedes Executive Order 2020-91 issued on May 18, 2020.

This Executive Order requires all businesses currently operating to implement certain safeguards to protect employees and to prevent the spread of COVID-19 throughout the workplace. These safeguards have been tailored to fit the particular industry of the business. Specific to out-patient health-care facilities, employers must abide by 15 requirements including:

  • Post signs at entrance(s) instructing patients to wear a face covering when inside.
  • Limit waiting-area occupancy to the number of individuals who can be present while staying six feet away from one another and ask patients, if possible, to wait in cars for their appointment to be called.
  • Mark waiting rooms to enable six feet of social distancing (e.g., by placing X’s on the ground and/or removing seats in the waiting room).
  • Enable contactless sign-in (e.g., sign in on phone app) as soon as practicable.
  • Add special hours for highly vulnerable patients, including the elderly and those with chronic conditions.
  • Conduct a common screening protocol for all patients, including a temperature check and questions about COVID-19 symptoms.
  • Place hand sanitizer and face coverings at patient entrance(s).
  • Require employees to make proper use of personal protective equipment in accordance with guidance from the CDC and the U.S. Occupational Health and Safety Administration.
  • Require patients to wear a face covering when in the facility, except as necessary for identification or to facilitate an examination or procedure.
  • Install physical barriers at sign-in, temperature screening, or other service points that normally require personal interaction (e.g., plexiglass, cardboard, tables).
  • Employ telehealth and telemedicine to the greatest extent possible.
  • Limit the number of appointments to maintain social distancing and allow adequate time between appointments for cleaning.
  • Employ specialized procedures for patients with high temperatures or respiratory symptoms (e.g., special entrances, having them wait in their car) to avoid exposing other patients in the waiting room.
  • Deep clean examination rooms after patients with respiratory symptoms and clean rooms between all patients.
  • Establish procedures for building disinfection in accordance with CDC guidance if it is suspected that an employee or patient has COVID-19 or if there is a confirmed case.