How to Prepare for the Aftermath of COVID-19

by Steven M. Harris, Esq. •

Monitor and Maintain an Adequate PPE Supply

The OSHA personal protective equipment (PPE) standards require workers to use gloves, eye and face protection, and respiratory protection when warranted by job hazards, including a viral outbreak.

OSHA provisions essentially require employers to supply PPE for employees to establish a uniform standard of safety and a workplace free from hazards.

The bloodborne pathogens standard under OSHA applies to occupational exposure to human blood and other potentially infectious materials that typically don’t include respiratory secretions but can apply to these if visible blood is present. These provisions may apply to some sources of the virus, including exposures to bodily fluids that may be present in COVID-19 collection and testing procedures or during standard patient treatment.

These OSHA provisions essentially require employers to supply PPE for employees to establish a uniform standard of safety and a workplace free from hazards. PPE supplies were seriously depleted during the initial months of COVID-19, so providers should take the following steps to ensure PPE is available:

  1. Check for state governor and public health orders on PPE usage requirements.
  2. Take an inventory of current PPE and related medical supplies/equipment.
  3. Use the CDC’s PPE Burn Rate Calculator to determine your PPE usage rate.
  4. Estimate future months of PPE usage considering varying patient volume.
  5. Consider PPE optimization and conservation strategies, if possible.
  6. If periodic shortages or serious depletion occur, consider local suppliers/manufacturers.

Recent studies have noted that otolaryngologists are at increased risk for contracting COVID-19 and other transmissible pathogens due to their close contact with patients and frequent aerosolization of viral particles during procedures, thus justifying continued COVID-19 safety and hygiene precautions (Eur Arch Otorhinolaryngol. 2020;1–13; Int Arch Otorhinolaryngol. 2020;24:e129–e130).

Leverage Telemedicine Under Current Standards

Sweeping federal and state waivers provide considerable telemedicine flexibility during the COVID-19 pandemic in contrast to standard requirements , which can be cumbersome. (See “The Doctor Will See You Now” in the May 2020 issue of ENTtoday.) CMS increased available services, eliminated originating site restrictions, and made changes in reimbursement parity. Providers should consider how their practices and patients can benefit from continued or expanded telemedicine services and applicable federal waivers and state telehealth waivers, which are monitored through the Federation of State Medical Boards website.

If certain federal telemedicine waivers are no longer in place or have been modified prior to a COVID-19 resurgence, providers should offer telemedicine services only under traditional standards, which include, but are not limited to, complying with provisions under HIPAA, CMS, and the U.S. Drug Enforcement Administration.

Since the onset of the COVID-19 pandemic, both federal and state authorities have promoted telemedicine for treating patients as a way to reduce virus transmission and expand care to patients from the safety of their homes. Although significant progress has been made in offering virtual healthcare under these temporary measures, federal and state governments and regulatory agencies will need to take action to permanently retain these changes once the emergency period has lifted.