Getting Your Facility Ready to Resume Services During COVID-19

• Risk Assessment: Conduct an independent risk/hazard assessment to determine readiness to reopen. Consider reviewing OSHA’s overview of Hazard Recognition from the U.S. Department of Labor.

• Risk Mitigation Policy: Establish a sustainable policy to minimize risks. Employers can determine the policy with input from resources, including OSHA guidance. COVID-19 transmission mitigation strategies outlined by the CDC include the following:
  • Appropriate infection control policies
  • Policy for COVID-19 screening of staff, clients/patients, and accompanying individuals
  • Physical distancing policy for staff, clients/patients, and visitors in non-restricted areas of the facility--this policy should meet current local, state, and national recommendations for community isolation practices

• Policy for Screening, Contact Tracing, and Reporting: Ensure that the policy to identify and report any new cases detected within your work place is consistent with local, state, and national regulations. This includes the following:
  • Communication of the facility's infection control and safety policies to all employees, clients/patients, and visitors, including
    • Procedures for cleaning/disinfecting processes.
    • Daily staff and client/patient screening health checks (CDC Activities and Initiatives Supporting the COVID-19 Response and President's Plan for Opening American Up Again [PDF]). The Equal Employment Opportunity Commission (EEOC) gave employers the green light to take employees' temperatures to try to ward off the spread of Coronavirus in recent guidance. It is important to keep in mind that temperature taking is an imperfect measure. Some people with COVID-19 do not have a fever, and some people with a fever do not have COVID-19. Review the CDC's Symptoms of Coronavirus for a description of COVID-19 symptoms.
    • Plans to inform employees and clients/patients/students when a client/patient/student or employee in your work setting has been diagnosed with COVID-19 or has been knowingly exposed. This plan should maintain confidentiality as required by the Americans with Disabilities Act (ADA).. 
  • Informed consent—create a form to obtain written consent from patients regarding your risk and safety policy and any alternate models of service delivery that you may have to use to meed client needs. ASHA does not have a standard informed consent form because of the variability of state, local, and federal regulations.

• Policy for Infection Control and Physical Distancing: Refer to the CDC and the World Health Organization (WHO) [PDF] guidelines for infection control and physical distancing to create a sustainable plan for your practice. ASHA’s COVID-19-related resources adhere to CDC and WHO guidelines. ASHA Infection Control Resources for Audiologists and Speech-Language Pathologists can also provide relevant information. Consider implementing additional policies such as:
  • Have a policy for the use of masks and other PPE by staff and clients/patients/students.
    • Follow CDC: Strategies to Optimize the Supply of PPE and Equipment
    • Address the unique needs of certain populations in your work place, such as the use of masks by children or those with dementia. Require handwashing before and after treatment.
  • Have a cleaning policy (e.g., wiping down all surfaces between clients) following CDC and WHO guidance. o Automate payment (e.g., have a credit card on file, email invoices), when possible, to reduce physical contact with clients.
  • Limit direct contact of staff and clients/patients/students, including avoiding hugging and handshakes.
  • Give thought to how you will minimize physical contact in shared spaces like break rooms and restrooms.
  • Plan for how people will move through the building (e.g., hallways, stairwells, and elevators). 

• Policy for Precautions to Follow for the Use of Certain Procedures: Determine which procedures carry a higher risk of infection.
  • Refer to ASHA guidance on aerosol generating procedures and implementing voice treatment without endoscopic assessment.
  • Follow practice guidance offered by the facility, state, and other regulatory bodies for ordering or providing laryngeal imaging procedures.

• Business Continuity Plan: Have a plan in place to sustain work while implementing required physical safety guidance.
  • Financial sustainability
    • Have a policy in place stipulating that those with a fever or who are sick cancel their appointment and consider waiving their cancellation penalties or in the case of students, remain home.
    • Ensure the sustainability of in-person services by considering your work place needs related to PPE and the implementation of safety precautions for in-person services.
      • You may need to consider how your practice will address the additional costs.
      • Review your payer contracts and be aware that reimbursement rates prior to the COVID-19 pandemic have not likely changed to be inclusive of the increased costs for in-person service provision safety needs, nor for costs associated with transitioning to the provision of telehealth services.
    • Ensure in-person service sustainability with the additional costs of PPE and implementation of safety precautions for in-person services.
      • Review contractual agreements that set payer reimbursement amounts.
      • Consider increasing the bandwidth of service provision to address additional costs related to PPE and implementation of physical safety precautions for in-person services.
  • Scheduling
    • The volume and turnover of clients/patients/students may not be the same as it was before COVID-19. Extending your business or school hours and scheduling work shifts for staff may be necessary to meet your business needs and to allow for appropriate physical distancing.
    • When scheduling clients/patients/students, permit adequate time to clean and disinfect therapy spaces between appointments.
    • Schedule in-person individual sessions rather than group sessions when possible.
    • Continue remote work whenever possible.
  • Waiting rooms
    • Limit who can attend visits to reduce the number of people coming in and out of facilities.
    • Close the waiting area, or set up the waiting area to conform with physical distancing guidelines.
    • Remove seats to allow for physical spacing, and designate clearly marked spaces on the floor to establish safe distances from the reception desk and between clients/patients/students in line. 
    • Remove toys, magazines, brochures, and other multiuse items.
    • Use plexiglass barriers on countertops, where appropriate.

• Facility Ramp-Up Plan: Create a plan to ramp up clinical services, giving consideration to the unique practice needs for the setting. The plan is typically slow and tiered, to ensure that the work place can accommodate the modifications effectively. Factors to consider include the following:
  • Access to PPE (e.g., gloves, face masks, and eye protection) that meets the clinical needs of the population served at the facility (e.g., type of diagnoses, volume of clients). Clear face masks will allow clients/patients/students to see the clinician’s mouth and facial expressions.
  • Clinical diagnoses encountered in the work setting.
  • Number of individuals who have tested positive for COVID-19 and persons under investigation (PUI) for COVID-19 encountered in the work place.  
  • Insurance coverage for and/or client/patient/student access to telepractice.
  • Ability to limit disease transmission within the setting.
  • Clinical needs typically encountered in the work place (e.g., need for instrumental assessments of voice and swallowing, mechanical ventilation, earmold impressions, otoscopy, etc.).
  • Availability of client/patient/student family members or others to serve as facilitators or extenders to implement hands-on procedures as needed.
  • Staffing availability. 

Clinicians and their facilities are encouraged to revisit their plans to resume care frequently to ensure that they comply with local, state, and federal regulations and are appropriately meeting client/patient/student needs while ensuring the safety of staff and clients/patients/students. Ramp-up plans may have marked regional variation depending on (a) local laws and (b) local prevalence and recovery from COVID-19. If conditions change, be prepared to step back to a phase that has more restrictions.

Additional Resources for In-Person Practice and Use of Higher Risk Procedures

American Occupational Therapy Association – Decision Guide Phased Reopening COVID19 Pandemic  [PDF]

American Psychological Association – COVID-19 Informed Consent

American Psychological Association – When Is It OK to Resume In-Person Services?

National Safety Council – SAFER: Safe Actions for Employee Returns