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patients. Alternately, unvaccinated patients might be seen during only certain hours, such as the beginning or end of the day.
Staying Diligent
Some patients have refused to wear masks during the pandemic for various reasons, and now other patients may not understand that the CDC’s reducing of masking protocols for fully vaccinated patients does not apply to healthcare settings. Thus, when making appoint- ments for in-office visits, practice staff should continue to set expectations prior to patients coming into the office regarding established infection control protocol. Patients should be informed that continued adherence to masking protocol is required. Patients also should be reminded that individuals in healthcare settings are often sick, immunocompromised, and in close proximity to one another, creating the potential for more expo- sure. Signage on the practice website, on the front door, and at the reception area will help alert patients that infection control protocols are still in effect.
If the patient is uncooperative upon arrival, health- care providers should ask the patient to step aside to a private area and acknowledge the patient’s concerns. If the patient is angry, they should be reminded that the practice is obligated to follow guidelines from the CDC as well as other government mandates, and that all in- fection control policies remain in place to ensure every- one’s safety. If the patient remains emotionally volatile and uncooperative, a healthcare provider can suggest the patient seek care with another healthcare provider.
Per the CDC, cloth face coverings should not be
used by those who are unable to remove the masks themselves, who have trouble breathing, or who are children under age two. Further, when requiring mask- ing, patients protected by the ADA must be carefully evaluated to avoid a claim of discrimination to the Office for Civil Rights. Please see these examples and explana- tions of why some patients may legitimately decline to wear a mask.
Vital Pandemic Recordkeeping
Continue to maintain records of staff-patient contact, i.e., who was assigned to work with the patient, either in a log or in the electronic health record. Document
so that you can track and notify contacts in case of a COVID-19 diagnosis or probable exposure on either the patient or provider side.
Further, to protect your practice, file records of staff screenings and screenings of those entering your facility in your administrative records, as well as maintaining records of all protocols and updated policies your office is following throughout this crisis. Keep records of PPE supplies/shortages, cleaning protocols followed, com- munications with patients, case incidence, and available medical resources within your community. Documenta-
SEPTEMBER/OCTOBER 2021 | WWW.OCMS-MI.ORG
tion that you have taken steps to follow recommended infection control protocol may be your best defense should COVID-19-related litigation occur in the future. For details, see COVID-19 Administrative and Medical Record Documentation: Prepare for Future Lawsuits.
OSHA Weighs In
More than a year beyond the start of the pandemic, the Occupational Safety and Health Administration (OSHA) released its new Emergency Temporary Standard (ETS) for COVID-19 on June 10, 2021, with an effective date of June 15, 2021. Impacted healthcare em- ployers 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). See the standard, including a fact sheet, on the OSHA website: COVID-19 Healthcare ETS.
Planning for a Vaccine
Vaccine Distribution: With vaccines more readily available within most communities (e.g., from local phar- macies and grocery chains), practices should evaluate access to the vaccine for their patients and make plans to determine if and how they will handle administering a vaccine, should this be an option. Many medical practic- es are partnering with state and local governments to provide vaccine clinics within the community, particular- ly in rural areas.
Informed Decision Making: As the COVID-19 vaccine rollout continues across the United States, medical practices should implement plans to educate patients and guide them to an informed decision about the vac- cines available within their community. Vaccine informa- tion sheets are available through the Food and Drug Ad- ministration (FDA) website: Pfizer-BioNTech—Fact Sheet for Recipients and Caregivers, Moderna—Fact Sheet
for Recipients and Caregivers, and Janssen (Johnson & Johnson)—Fact Sheet for Recipients and Caregivers. The CDC also provides easy-to-understand fact sheets for patients on its website: Benefits of Getting a COVID-19 Vaccine and Myths and Facts about COVID-19 Vaccines. For additional information, see The Doctors Company Communicating With COVID-19 Vaccine-Hesitant Pa- tients: Top Tips.
Vaccine Administration: If your practice is designated as a vaccine administration site, establish policies and procedures for storage and inventory, scheduling and patient screening, patient education, documentation and patient follow-up, and the management of med- ication errors and emergencies. If you are assigned a state-sponsored vaccination team to administer vac- cines within your facility on your behalf, review the state’s protocols to ensure that its practices are safe, and inform patients that the vaccine administration is being conducted by the state. The CDC provides guid- ance on vaccine storage and handling best practices,
a training module for healthcare professionals, and
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