Effective May 1, Ohio Director of Health Dr. Amy Acton rescinded her March 17 Order for the management of elective and otherwise “non-essential” health care services, surgeries and procedures. In its place, the Director has cleared health care providers to render all outpatient procedures, treatments and diagnostic tests (including surgeries and dental care services) which do not require an inpatient hospital admission or an overnight stay in a healthcare facility. This means that all regular practitioner visits, outpatient surgeries and procedures, diagnostic testing, imaging services, and dental care procedures, may resume. Further, all ‘essential’ medical procedures (as described below) may continue to be provided to patients by Ohio healthcare providers.
The Director’s Order is welcome news for providers who have seen their revenues drop precipitously as patient care services slowed to a trickle over the past several weeks. However, there are conditions to resuming services. Providers must determine that they can implement the necessary precautions to reduce the risks of the spread of COVID-19 infection, and be prepared to respond to a potential surge in COVID-19 cases before they resume services. Conditions for resuming services include:
- Following infection control and environmental practices requirements per Ohio Department of Health (ODH) and Centers for Disease Control (CDC) guidelines
- Maintaining adequate inventories of personal protective equipment (PPE), supplies, equipment and medication to treat patients, considering all phases of care
- Developing plans for the reuse and/or preservation of PPE, supplies and equipment, as well as processes to maintain an up to date inventory count of all available PPE
- Ensuring access to a reliable supply chain sufficient to support continued operations for non-COVID-19 cases, as well as for any surge in COVID-19 cases
- Defining processes for testing patients and staff for COVID-19 in accordance with ODH guidelines
- Continued use of telehealth whenever possible
- Developing action plans for communication, outreach and equitable delivery of services
To the extent that a provider determines that it cannot meet the above conditions, or that restarting certain types of outpatient services or procedure would compromise its ability to respond to a surge in COVID-19 cases, then it should not restart those services.
One factor to consider in determining how to resume non-essential services includes determining whether the provider can secure access to COVID-19 testing for the increased numbers of patients and personnel who will be coming into its facilities. Some hospital systems are initially restarting outpatient procedures only to the extent that it can ensure access to such testing. Regardless, every provider must have a plan in place to screen all patients prior to rendering services. This may include in-home screenings conducted by the patient, as well as and in-person screenings at the facility through the use of questionnaires, temperature and other symptom checks prior to providing services.
Providers should also consider developing COVID-19 specific informed consent procedures to ensure that patients are fully advised of the risks of choosing to move forward with services, and the potential for infection during or post-treatment.
Assuming that all of these conditions can be met, providers next need to consider which services and procedures to prioritize, and which patients should be treated first.
First, telehealth services should continue to be utilized whenever possible.
Next, prioritization must be given to those patients who have delayed needed procedures, or those with new diagnoses. Critically, “essential” surgeries and procedures which may nevertheless have been delayed even though they were not covered by the Director’s March 17 Order should go on the top of that list. These include any procedure where: (i) there is a threat to the patient’s life if the surgery or procedure is delayed; (ii) there is a threat of permanent dysfunction of an extremity or organ system if the procedure is delayed; (iii) there is a risk of metastasis or progression of staging if the procedure is delayed; (iv) there is the presence of severe symptoms causing an inability to perform activities of daily living; and (v) there is a risk of rapidly worsening symptoms if the procedure is delayed. Only after essential treatments have been addressed for patients should providers move to restart other elective services which the provider evaluates can be rendered within the conditions set by the Director’s Order.
In short, healthcare providers may resume all medical care, treatment, tests and procedures that can be provided to patients on an outpatient basis, and may continue to perform essential procedures in all cases. With respect to non-essential services, these services may be resumed only after conducting a risk assessment to determine whether those case can be provided in a manner that protects patients, limits the risk of COVID-19 infection, and ensures that providers remain able to meet a surge in COVID-19 cases. If providers do not believe that they can maintain sufficient PPE, critical equipment, supplies or other resources, then they should continue to limit the number of non-essential services they perform for the time being.