CMS Recommendations on Reopening Facilities to Provide Non-Emergent Healthcare Services

April 27, 2020
David Jose and Jennifer Stuart
SmithAmundsen Health Care Alert

On April 19, 2020 the Centers for Medicare & Medicaid Services (CMS) issued new guidelines for health care providers in re-opening to provide non-emergent in-person services. This follows upon on its recommendations issued on March 18 limiting non-essential care in order to expand capacity to care for patients with COVID-19 and conserve staff, supplies, and personal protective equipment.

CMS recognizes that many areas have a relatively low and stable incidence of COVID-19, and it wants to acknowledge and provide guidance for a gradual “re-opening” process that can include care for patients whose non-emergent services have been deferred. This will be especially important for hospitals and surgery centers that have experienced a significant drop in revenue over the past several weeks as resources and space have been shifted towards COVID-19 patients and preparedness.

These recommendations from CMS are intended to be applied in conjunction with the Guidelines for Opening Up America Again issued by President Trump on April 16. These would be appropriate for facilities in an area that has moved into Phase 1 of that 3-Phase approach. This would be an area where there is a downward trajectory of cases and positive tests over a 14-day period, and where hospitals are able to follow a robust testing program for patients and all health care workers.

CMS does not provide a single set of metrics or a specific process to be followed. Instead, it highlights considerations for health care providers to make cautious, case-by-case decisions. These considerations include:

CMS noted that these are recommendations to help guide healthcare systems and facilities as they consider resuming in-person care in regions with a low incidence of COVID-19 disease. As a result, this is a process that facilities should be preparing for now. At the same time, CMS also cautions that facilities should also be prepared to cease non-essential procedures again if there is a surge.