Re-Opening in a Covid-19 World: Considerations for Practitioners When Re-Opening Your Physical Office
Re-Opening in a Covid-19 World: Considerations for Practitioners
Of all the hot topics being debated among practitioners as of July 2021, the topic of whether, and how, a clinician should reopen their physical office space is at the forefront of many discussions. And yet, this is a tricky topic, and more so than other compliance-related issues in some ways. Whereas other advice regarding compliance issues may be pretty straightforward and mostly unchanging, the same cannot be said in regards to compliance issues and Covid-19. Even with the success of the Covid-19 vaccines (a historic scientific breakthrough in itself), Covid-19 is still a major global health concern, is still mutating, and still being transmitted (as evidenced by the rapid spread of the “Delta” variant as well as other strains of Covid-19).
We live in unprecedented times: the last time the world had a global viral pandemic of this magnitude was 1918, when the Spanish Flu was devastating human populations across the globe. The world of 2021, both in terms of healthcare and law, is vastly different from the world of 1918 (for example: there was no HIPAA in 1918!) So, a forewarning: the considerations discussed in this blog as of the time of this writing, may not be relevant or accurate six months, nine months, or a year or more from now.
One of the first things you must know as an ethical practitioner focused on protecting your practice is that it is your responsibility to know what your local and state rules and regulations are. CDC guidelines are just that---guidelines. Each state has jurisdiction over themselves and regulations governing their residents; often they are different from one state to another. For example, consider Florida vs other states which implemented very strict public mask laws in the last year. Florida enacted very few. So as you develop policies on re-opening, you must be taking your own state’s laws and regulations into account.
One of the primary focuses practitioners should have when re-opening their physical office is ensuring they can do so in a manner that protects the health and safety of their staff, clients, and guests.
To prepare for returning to the office, consider the following when making your decision:
1). Know what your local and state guidelines regarding Covid-19 are with regard to operating a business;
2). Establish procedures, written down of course, for staff on how to return to the office. Policies will vary from practice to practice but can include:
Policies and Procedures regarding physical distancing requirements;
Policies and procedures on how to handle clients and scheduling appointments and their arrival and visits to the office;
Procedures for when first arriving into the office and leaving at the end of the day;
Procedures for masks in the office---who wears them and when, if applicable. (For example, if you have adults and kids coming into your office, unvaccinated kids should potentially be wearing masks!)
Procedures for office hygiene and health---wiping down desks, hand-washing, use of sanitizers, etc.
Procedures for staff self-screening in the event a staff member develops symptoms of illness either in the office or prior to their arrival at the office on any given day;
Procedures for how to handle potential Covid-19 exposure within the office, and/or if by a staff member unknowingly, who then comes into the office;
Amending staff sick leave policies to be more flexible related to allowing staff to leave early, take time off, or work from home, if needed, as a precaution (do you really want an employee exhibiting Covid-19 symptoms coming into or staying in your office?!)
3). Establish procedures, written down of course, for clients and guests visiting the office. This can include:
Policies and Procedures regarding physical distancing requirements;
Policies and procedures on how to handle clients and scheduling appointments and their arrival and visits to the office;
Procedures for clients when they are arriving, waiting, attending sessions, and leaving the office;
Daily sign-in lists for clients (this can be especially crucial in the event there is in-office exposure to Covid-19. You now have a record of who was in the office and when, and who they were in contact with)
Procedures for office hygiene and health---use of a “clean” and “dirty” pen box, hand sanitizer units, etc.;
Procedures for staff self-screening in the event a client develops symptoms of illness prior to their appointment within the office;
Procedures for how to handle potential Covid-19 exposure within the office, and/or if by a guest or client unknowingly, who then comes into the office;
If you have any sort of fees or policies regarding last-minute cancellations or rescheduling of a client appointment, you may want to provide an exception in the event of illness, including waiving fees for cancellation in the event a client calls in sick.
In addition to the above, there are some other measures you may want to consider prior to opening your physical office.
One option is to identify what interests your clients (and your staff!) may have regarding returning in-person to the office; you can conduct a survey to gauge interest. This may be useful for two reasons. First it may provide you data which can help you understand if now is the right time to re-open your office. Secondly, though, it may also provide data regarding who is going to be utilizing your office space. Dan has advised he knows of practices that have surveyed their clients and found a certain percentage will not return to the office, and prefer to remain using teletherapy. This is incredibly useful knowledge, and it is also an opportunity! For example, if prior to the start of the Covid-19 pandemic, you had 100% utilization of your offices provided for therapy clients, but now have 40% of your clients indicating they will only do teletherapy going forward, this offers you an opportunity to expand your client base (and even hire!). If you have a wait list, or if you are taking on new clients, you now have space you may not have had before to add clients, while still keeping the same number you may have had before! That’s an incredible opportunity!
Another option to consider is to implement some sort of Covid Waiver for clients, and a Covid Acknowledgement form for staff. The Covid Waiver for clients should spell out all of your office’s policies you are implementing to ensure the health and safety of clients when they visit the office. Please note, as the Covid Waiver involves the potential waiving of legal rights, you really need to consult with an attorney before implementing one. If you do decide to implement a Covid Waiver, it should detail all of the policies we discussed above--remember this is to inform clients and make them aware of the office Covid policies, so this is very important. Finally, and this will depend on your local and state laws, you may be able to have clients sign a statement providing your office indemnity and have the clients acknowledge and sign to willingly accept the potential risks of coming into the office for therapy treatment (versus teletherapy). Again, this last point is very much going to be determined by your state and local laws, and given the legal nature of the last part, you should absolutely consult an attorney before you try to implement a client Covid Waiver.
A Staff Acknowledgment form, as we refer to it, is a written document for your staff to have. Again, it lays out for the staff all of the Covid policies you are implementing and what you want them to do to help keep the office a safe and healthy place to work. It should also detail for your staff all of the policies you are implementing for clients, so they know what the policies are they should have clients follow and help enforce those policies.
If you do not own your own practice, or you work at an agency or group practice, check in with your supervisor to find out what the policies they are implementing are, if they are re-opening their physical office space. Make sure that you are abiding by your office’s policies to keep you and your clients safe.
Remember, we are in unprecedented territory here! Remember, we are in unprecedented times! Everyone is doing their best to figure out how to navigate these times, and what the best procedures and policies are. Give yourself a break, you may make mistakes, and that’s ok. But be willing to recognize when you need help, and get it, if you do. Whether it’s an HR consultant, an attorney, or a HIPAA compliance specialist, it’s ok to ask for help!
Also, remember, nothing we suggest here, and nothing you implement will ever be 100% fool-proof. You cannot hermetically seal your physical office and still reopen; this is the risk of re-opening. But it doesn’t mean you shouldn’t necessarily re-open your physical office space. Implementing policies and procedures for re-opening means you are making your best effort to provide a safe and healthy office space for clients, guests, and staff. It also means you have plans in place in case of Covid exposure in the office and have a plan to follow swiftly and efficiently if it does happen.
Enjoyed What You Just Read?
Check out Episode #13 on “Re-Opening Your Office After Covid-19: Things You Need to Know!” to hear what else Melissa and Dan have to say on this topic.
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