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CMS Recommendations for Reopening Healthcare Facilities


Even though health experts have expressed doubt in America's readiness to "open up" the economy, it is clear that elected representatives are working towards that end.

Georgia Governor Brian Kemp was the first to reopen some nonessential businesses “on a limited basis” to help reinvigorate Georgia’s economy before lifting the state’s month-long shutdown on April 30. Oklahoma is on track to begin its phased reopening Friday, May 1. Missouri Gov. Mike Parson's plan is to reopen businesses May 4. Kansas Democratic governor Kelly has not yet set a date for phased reopening.

For the economy to reopen, three conditions need to be met:

1. Health systems across the country must have the capacity to deal with a rise in new coronavirus infections.

2. The rate of infections, hospitalizations and deaths must be declining.

3. Testing capacity needs to be strong enough to quickly isolate potential

The first two criteria have been met. Currently the main objection to reopening
is the limited ability to perform Covid-19 testing, which infectious disease experts say is key to enable a safe reopening.


Monday, April 27 the White House announced a new federal plan for COVID-19 testing. The plan, which will be "federally supported, state managed, and locally executed," includes three core elements:

1. Increase lab supplies and the ability to collect test samples.

2. A timely monitoring system that will diagnose those who are symptomatic, and proactively work with higher risk individuals.

3. CDC should work with local governments to ensure symptomatic and
asymptomatic cases are quickly identified and traced.

The federal government aims to give states the ability to test at least 2% of their populations each month. Testing capacity will be expanded to allow for 2 million tests per week, with many businesses in the private sector, such as CVS and Walgreens, increasing production and accessibility.


CMS has recognized that many areas have a relatively low and stable incidence of COVID-19, and that it is essential to allow facilities to provide care for patients needing non-emergent, non-COVID-19 healthcare services that have been postponed. i.e. surgeries, chronic disease care, preventive care and other procedures.

If states or regions pass the Gating Criteria (symptoms, cases, and hospitals) announced on April 16, 2020, then they may proceed to Phase I in opening their facilities to non-Covid-19 cases. Maximum use of all tele-health modalities is strongly encouraged. However, for care that cannot be accomplished virtually, the following recommendations may guide healthcare systems and facilities as they consider resuming in-person care
of non-COVID-19 patients.

Decisions should be consistent with public health information and in collaboration with state public health authorities.


Careful planning is required to resume in-person care of patients requiring non-COVID-19 care, and all aspects of care must be considered.

For example:
1. Adequate facilities, workforce, testing, and supplies
2. Adequate workforce across phases of care such as availability of:

  • Clinicians

  • Nurses

  • Anesthesia

  • Pharmacy

  • Imaging

  • Pathology support

  • Post-acute care


General Considerations

The following recommendations are intended to give healthcare facilities flexibility in providing essential nonCOVID-19 care to patients without symptoms of COVID-19.

1. Evaluate the incidence and trends for COVID-19 in the area where re-starting in-person care is being considered. Coordinate with State and local public health officials.

2. Evaluate the necessity of the care based on-clinical needs.

  • Prioritize surgical/procedural care and high-complexity chronic disease management.

  • Some preventive services may also be highly necessary.

3. Consider creating Non-COVID Care (NCC) zones

  • Screen all patients for COVID-19 symptoms, including temperature checks.

  • Routinely screen staff and others who work in the facility (physicians,

nurses, housekeeping, delivery and all who would enter the area).

4. Ensure sufficient resources are available to the facility across phases of
care without jeopardizing surge capacity.

  • PPE

  • Healthy workforce

  • Facilities, supplies, testing capacity

  • Post-acute care


Workforce Availability

1. Staff should be routinely screened for symptoms of COVID -19 and if symptomatic, they should be tested and quarantined.

2. Staff who will be working in these NCC zones should be limited to working in these areas and not rotate into  “COVID-19 Care zones”

3. Staffing levels must remain adequate to cover a potential surge in COVID-19 cases.

Facility Considerations

1. Create areas of NCC which have in place steps to reduce risk of COVID-19 exposure and transmission.

2. These areas should be separate from other facilities to the degrees possible (i.e., separate building, or designated rooms or floor with a separate
entrance and minimal crossover with COVID-19 areas).

3. In the facility’s administration and engineering, controls should be established to facilitate social distancing.

  • Minimize time in waiting areas

  • Space chairs at least 6 feet apart

  • Maintain low patient volumes.

4. Visitors should be prohibited but if they are necessary for an aspect of patient care, they should be pre-screened in the same way as patients.


Sanitation Protocols

1. Ensure that there is an established plan for thorough cleaning and disinfection prior to using spaces or facilities for patients with non-COVID-19 care needs.

2. Ensure that equipment such as anesthesia machines used for COVID-19 (+) patients are thoroughly decontaminated, following CDC guidelines.

1. Adequate supplies of equipment, medication and supplies must be ensured.

2. The facility should be able to respond to a potential surge.

Testing Capacity

1. Screen all patients for potential symptoms of COVID-19 prior to entering the NCC facility.

2. Routinely screen staff for potential symptoms.

3. Whenever possible, patients should be screened by laboratory testing before care.

4. Staff working in these facilities should be regularly screened by laboratory
test as well.

All facilities should continually evaluate whether their region remains a low risk of incidence and should be prepared to cease non-essential procedures if there is a surge. By following the above recommendations, flexibility can allow for safely extending in-person non-emergent care in select communities and facilities.



Strategies to Optimize the Supply of PPE and Equipment
Personal protective equipment (PPE), used to protect staff, patients and others
when providing care, includes the following:


  • Eye Protection

  • Isolation Gowns

  • Facemasks

  • N95 Respirators

  • Decontamination and Reuse of Filtering Facepiece Respirators

  • Ventilators

  • Powered Air Purifying Respirators

Guidelines for preserving PPEs can be found at:

CDC Guidelines for Opening Up America Again are found at:






We welcome your comments and questions

contact Donald Tapella at Medical Recovery Services


Phone: (816) 229-4887, ext.112

Fax: (816) 229-4787

visit our website at

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