CMS Issues Recommendations to Reopen Health Care Systems in Areas with Low Incidence of COVID-19  

April 20, 2020

Following federal guidelines announced last Thursday by President Donald Trump, states are moving to reopen in phases amid the coronavirus pandemic (federal guidelines). On Sunday, April 19, 2020, CMS also released updated recommendations for how hospital systems can begin to reopen as well (CMS guidance).

To increase capacity to care for COVID-19 patients and to conserve adequate staff and supplies, especially personal protective equipment (PPE), on March 18 the Centers for Medicare & Medicaid Services (CMS) recommended limiting nonessential care and expanding surge capacity into ambulatory surgical centers and other areas. However, CMS now believes that, at this time, many areas of the country have a low, or relatively low and stable incidence of COVID-19 infection. As a result, CMS  has issued recommendations to allow health care facilities in areas where there is a lower prevalence of COVID-19 to provide care for patients needing non-emergent, non-COVID-19 health care. The purpose of the newly issued CMS guidance is to afford flexibility to health care systems in order to allow them to provide “essential non-COVID-19 care to patients without symptoms of COVID-19 in regions with low incidence of COVID-19.”

The CMS guidance includes several components that must be considered by a health care provider before reopening to treat patients without COVID-19, some of which include:

  • Collaboration with state and local public health officials to  evaluate whether restarting/reopening in the area is prudent based on incidence and trends of COVID-19 infections.
  • Evaluating the necessity of the care based on clinical needs. For example, providers should prioritize surgical care and high-complexity chronic disease management; however, select preventive services may also be highly necessary.
  • Ensure that sufficient resources (e.g., personal protective equipment) are available for all phases of care “without jeopardizing surge capacity.”
  • Usage of personal protective equipment by health care workers and patients.
  • Routine screening and testing of staff for COVID-19.
  • Ensure routine sanitation protocols.
  • Ensure adequate medical supplies/equipment/medication.
  • Screening of patients for COVID-19 prior to entering health care facilities

Even if a health care facility decides to reopen, CMS emphasizes that “[a]ll facilities should continually evaluate whether their region remains a low risk of incidence and should be prepared to cease nonessential procedures if there is a surge.”

CMS’s guidance may be found here.

The federal guidelines for the phased approach to opening up the country can be found here.


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Gregory M. Fliszar

Vice Chair, Health Care & Life Sciences

(215) 665-4737

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