Reopening Your Outpatient Clinic During The Pandemic
My life before using the phrases “flatten the curve” and “social distancing” seems like a dream. This year has been quite a challenge for everyone, including private practice owners. Before mid-March we were growing at a comfortable rate. We had recently hired more staff to help us continue towards our goals, had systems in place and running, Our clinic was seeing over 500 physical therapy visits per week, our gym membership was growing, our massage program was getting some traction, and we had a strong winter season with little to no disruptions due to weather. Everything was right in our world…until it wasn’t. Now, reopening seems like it’s a long way off.
Covid-19 has certainly changed what we envisioned the year 2020 to be. As I watched the virus make its way across the United States, I knew we were in for disruptions to our plans. On March 16th we made the decision to protect our clients and employees by closing for two weeks to give us time to assess and make important decisions. Since then it has been non-stop changes, scrambling, and trying to keep up with laws, regulations, rules, and amendments to those rules. Working 14-hour days gave me flashbacks to when we first opened, and when we grew the practice into a larger facility. At the end of each week I made a conscious effort to remind myself of why we started the practice in the first place, and envision the day when we will be back to where we were before this virus entered our lives.
With the return of patients and staff, we need to remember that the pandemic is not over. We will return to “the new normal” and need to plan accordingly in order to offer the highest level of protection to our clients and staff. Here are some things to consider when doing so during reopening:
Maintain awareness of CDC guidelines when reopening. Some of the recommendations to keep in mind in outpatient clinics are:
- limiting face-to-face contact whenever possible
- frequently washing hands
- using face coverings for all employees and clients (when it does not negatively impact their health)
- creating at least six feet of space between individuals
- routinely cleaning and disinfecting all surfaces and equipment
Implement these throughout the clinic and staff areas. Some ideas to do so are:
- Break room areas and shared workspaces: develop a strategy for reconfiguring shared workspaces for social distancing. If possible, move employee desks to at least 6 feet apart. Limit the number of employees allowed in any shared areas at the same time. Implement cleaning and infection control protocols for desks, refrigerators, microwaves. In high-traffic work areas, either create individual workstations or implement cleaning protocols to reduce the spread of infection via computer hardware and office equipment.
- Waiting room: Consider how to reduce the number of people waiting in this area. Clinics can consider having patients wait outside in their car until their appointment time. Space out seating by 6 feet. Do a virtual or verbal check-in instead of a sign in sheet.
- Clinic operations: stagger therapist work schedules. Consider opening on weekends to further space out treatment times and staff schedules. Implement telehealth to allow virtual visits when appropriate.
Reduce risk infection in the clinic
For guidance you can review OSHA Guidance on Preparing Workplaces for COVID-19 (https://www.osha.gov/Publications/OSHA3990.pdf) when developing your protocols for infection control, testing and monitoring, and PPE use. These guidelines follow CDC standards and recommend workplace controls based on exposure risk levels. Here are a few highlights from it:
- Implement policies for reducing exposure, including educating patients on COVID-19 symptoms, and instructing them to cancel in-person sessions if they are sick.
- Post signs in your clinic describing COVID-19 symptoms and educate patients to bring their own mask if it is not a hazard to their medical condition/health
- Consider implementing an employee testing and monitoring plan to prevent outbreaks.
- Provide employee training about infection control, COVID-19 symptoms, and your new post-pandemic policies
- Make sure you have plenty of cleaning and sanitation supplies. Have hand sanitizer, soap, and cleaning supplies readily available to coincide with your new protocols for cleaning treatment areas.
- Remove equipment and supplies that are not easy to disinfect, such as therapy putty, play dough, bean bags, and cloth chairs.
- Provide your employees with masks and gloves.
The Department of Labor offers guidance on OSHA standards during the pandemic: https://www.osha.gov/SLTC/covid-19/additional_resources.html
Employee management after reopening
At the first sign of illness staff members should be educated to stay home and contact their doctor to seek testing. Employers are not to share any identifiable information about the ill employee, as that would be a breach of workplace privacy laws. You should, however, alert people that you have reason to believe he or she has been in contact with someone who has either tested positive for COVID-19 or is exhibiting symptoms. Emphasize that, while there is no cause for immediate alarm, the person may wish to seek the advice of their doctor while monitoring for symptoms.
There have been many questions about an employer’s right to take employee temperatures. The Equal Employment Opportunity Commission (EEOC) considers taking an employee’s temperature to be an unlawful “medical examination” under the ADA. The ADA prohibits employee medical examinations unless they are “job-related and consistent with business necessity.” Generally, a medical examination of an employee is job-related and consistent with business necessity when an employer has a reasonable belief, based on objective evidence, that: an employee’s ability to perform essential job functions will be impaired by a medical condition, or an employee will pose a direct threat (i.e. a significant risk of substantial harm even with reasonable accommodation) due to a medical condition.
On March 11, 2020, the World Health Organization (WHO) declared COVID-19 a pandemic. The EEOC’s guidance on pandemics says that if pandemic symptoms become more severe than the seasonal flu or the H1N1 virus in the spring/summer of 2009 (as they have with COVID-19), or if a pandemic becomes widespread in the community as assessed by state or local health authorities or the CDC, then employers may measure employees’ body temperature.
Carefully reopening your practice involves much staff and client education, collaboration with experts and teamwork. Keep in mind that during the pandemic things are rapidly changing and evolving, so it is vital to keep on top of rules, regulations, and changes.