The State of California aims to move into Stage 2 of the state’s reopening plan by the end of this week (May 8), allowing the return of retail, manufacturing and other “low-risk businesses.” New physical distancing measures should be followed and implemented in order for these businesses to reopen.

Additionally, the Centers for Medicare and Medicaid Services (CMS) has issued updated guidance for healthcare providers previously restricted from providing non-essential healthcare to reopen and transition to in-person care for non-emergent, non-COVID-19 conditions.


On March 18, 2020, CMS recommended to limit non-essential care and expanding surge capacity into ambulatory surgery centers and other areas, thus allowing expanded capacity to care for those patients with COVID-19 and to conserve adequate staff and supplies, especially personal protective equipment (PPE).

CMS Reopening Criteria

CMS recognizes that at this time many areas have a low or relatively low and stable incidence of COVID-19 and that it is important to be flexible and allow facilities to provide care for patients needing non-emergent, non-COVID-19 health. Services such as certain procedural care (surgeries and procedures), chronic disease care and, ultimately, preventive care will be allowed to be performed again.

Patients continue to have ongoing healthcare needs that are currently being deferred. Therefore, if states or regions have passed the Gating Criteria (symptoms, cases and hospitals) announced on April 16, 2020, then they may proceed to Phase I.

The Guidelines for Opening Up America Again can be found by clicking here.

CMS Reopening Recommendations

CMS strongly recommends continuing to maximize the use of telehealth modalities. However, care that cannot be accomplished virtually, CMS issued recommendations to guide healthcare systems and facilities as they consider resuming in-person care of non-COVID-19 patients in regions with low incidence of COVID-19 disease.

Providers will need to evaluate:

  • Access to and availability of PPE
  • Availability of their workforce
  • Facility readiness
  • COVID-19 testing capacity

This analysis will help as healthcare providers strive to protect patients’ safety as health centers and clinics resume the provision of non-essential healthcare services once state or local restrictions are lifted.

In coordination with state and local public health officials, it is important for healthcare providers to evaluate the incidence and trends for COVID-19 in the area where re-starting in-person care is being considered. Considerations should include:

  • Evaluating the necessity of the care based on clinical needs. Providers should prioritize surgical/procedural care and high-complexity chronic disease management; however, select preventive services may also be highly necessary.
  • Establishing Non-COVID Care (NCC) Zones that would screen all patients for symptoms of COVID-19, including temperature checks. Staff would be routinely screened as would others who work in the facility (physicians, nurses, housekeeping, delivery and all people who would enter the area).
  • If sufficient resources are available to the facility across phases of care, including PPE, healthy workforce, facilities, supplies, testing capacity and post-acute care, without jeopardizing surge capacity.

Considerations for Reopening

Healthcare systems or clinicians have flexibility to re-start clinically necessary care for patients with non-COVID-19 needs or complex chronic disease management requirements in accordance with the following considerations:

  • PPE: Healthcare providers and staff should wear surgical facemasks at all times. Patients should wear a cloth face covering that can be purchased or made at home if they do not already have surgical masks. Every effort should be made to conserve PPE.

  • Workforce Availability: Staff should be routinely screened for symptoms of COVID-19, and if symptomatic, they should be tested and quarantined. Staff who will be working in these Non-COVID-19 Care Zones should be limited to working in these areas and not rotate into “COVID-19 Care Zones” (e.g., they should not have rounds in the hospital and then come to a Non-COVID-19 Care Facility). Staffing levels in the community must remain adequate to cover a potential surge in COVID-19 cases.
  • Facility Considerations: When providing in-person, non-emergent care, the facility should create areas of NCC that have in place steps to reduce the risk of COVID-19 exposure and transmission. These areas should be separate from other facilities to the degrees possible (i.e., separate building or designated rooms or floor(s) with a separate entrance and minimal crossover with COVID-19 areas). Within the facility, administrative and engineering controls should be established to facilitate social distancing, such as minimizing time in waiting areas, spacing chairs at least six-feet apart and maintaining low patient volumes. 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: Healthcare providers must establish and implement robust protocols for cleaning and disinfecting examination and procedure rooms, equipment and common areas to assure patient and staff safety. Equipment such as anesthesia machines used for COVID-19 patients must be thoroughly decontaminated following CDC guidelines.
  • Supplies: Adequate supplies of equipment, medication and supplies must be ensured and not detract from the community's ability to respond to a potential surge.
  • Testing Capacity: All patients must be screened for potential symptoms of COVID-19 prior to entering the NCC facility, and staff must be routinely screened for potential symptoms as noted above. When adequate testing capability is established, patients should be screened by laboratory testing before care, and staff working in these facilities should be regularly screened by laboratory test as well.

Healthcare providers are encouraged to develop contingency plans to address further disruptions to non-essential services should the public health emergency needs re-emerge.

Please reach out to GHJ’s COVID-19 Response Team if you have any questions as the firm has an experienced team of consultants specializing in cash-flow projections, strategy and operations consulting and re-organizations. We are here to assist organizations to succeed in these very challenging times.

Ben Sheppard Facts

Ben Sheppard

Ben Sheppard, CPA, is a managing director in GHJ’s Forensic Services Practice and has more than 35 years of experience. He has deep expertise in litigation support and expert witness services, as well as forensic investigations and valuations. Ben works closely with clients to helping them find…Learn More