As the COVID-19 situation begins to stabilize in many locations, the Centers for Medicare & Medicaid Services (CMS) has issued guidance on providing essential non-COVID-19 care to patients in certain locations. The announcement was made in coordination with the federal plan for Opening Up America Again. The CMS recommendations will serve as a guide to independent practices who may be able to re-open their practices in areas with a low incidence of COVID-19.
On March 18, CMS announced that all elective surgeries, non-essential medical, surgical, and dental procedures should be delayed during the 2019 Novel Coronavirus (COVID-19) outbreak. In making the most recent announcement, CMS Administrator Seema Verma said:
Today, some areas of the country are experiencing fewer cases and lower incidence of the virus, necessitating a more tailored and flexible approach. Every state and local official will need to assess the situation on the ground to determine the best course forward, but these guidelines provide a gradual process for restarting non-COVID-19 essential care while keeping patients safe.
The new CMS recommendations for providing essential care to patients without symptoms of COVID-19 are specifically targeted to communities that are in Phase 1 of the Guidelines for Opening Up America Again with low incidence or relatively low and stable incidence of COVID-19 cases.
In making the announcement, CMS emphasized the importance of restarting care that is currently being postponed, “such as certain procedural care (surgeries and procedures), chronic disease care, and, ultimately, preventive care.” The organization recognized that there are a number of patients who continue to have ongoing healthcare needs that have been deferred during COVID-19.
Independent practices located in states or regions that have passed the Gating Criteria regarding symptoms, cases, and hospitals that were announced on April 16, they may proceed to Phase I. Even so, CMS is strongly encouraging the maximum use of telehealth where appropriate.
The Gating Criteria includes:
- Symptoms: Downward trajectory of influenza-like illnesses reported within a 14-day period and downward trajectory of COVID-like syndromic cases reported within a 14-day period.
- Cases: Downward trajectory of documented cases within a 14-day period or downward trajectory of positive tests as a percent of total tests within a 14-day period (flat or increasing volume of tests)
- Hospitals: Treat all patients without crisis care and robust testing program in place for at-risk healthcare workers, including emerging antibody testing.
CMS states that non-COVID-19 care should be offered to patients as clinically appropriate and in an area that has the necessary resources to quickly respond to a surge in COVID-19 cases if necessary. The decision regarding whether to provide non-COVID-19 care should be consistent with public health information and in collaboration with state public health authorities.
All aspects of non-COVID-19 care should be considered, including:
- Adequate facilities, workforce, testing, and supplies
- Adequate workforce across phases of care (such as availability of clinicians, nurses, anesthesia, pharmacy, imaging, pathology support, and post-acute care).
Independent physicians within these areas should continually evaluate whether their region remains a low risk of incidence and should be prepared to cease non-essential procedures if there is a surge in COVID-19 cases.