The Centers for Medicare & Medicaid Services (CMS) issued recommendations to reopen health care systems in communities with low incident rates of COVID-19. This is outlined in Phase 1 of the White House Guidelines for Opening Up America Again. Per CMS, the guidelines “recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials, and to review the availability of personal protective equipment (PPE) and other supplies, workforce availability, facility readiness, and testing capacity when making the decision to re-start or increase in-person care.” It is important to note that there is no specific timeline related to the reopening guidelines. Read the CMS recommendations.

Our advocacy partner Epstein Becker Green has provided a summary of the Guidelines as it relates to elective surgery.

“Opening Up American Again” Gating Criteria: Under the White House guidelines, if a state or region has passed the “Gating Criteria,” the state or region may proceed to Phase I of the Opening Up America Again Plan. The “Gating Criteria” requires the following to be satisfied to proceed:

  • Symptoms: The state or region must have a downward trajectory of influenza-like illnesses and a downward trajectory of COVID-like syndromic cases reported within a 14-day period.
  • Cases: The state or region must have a downward trajectory of documented cases within a 14-day period or a downward trajectory of positive tests as a percent of total tests within a 14-day period (with a flat or increasing volume of tests).
  • Hospitals: Hospitals must be able to treat patients without crisis care and have a robust testing program in place for at-risk healthcare workers, including emerging antibody testing.

CMS Recommendations for Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare: Phase 1 

CMS enumerates more specific steps that should be taken by facilities, in coordination with local public health officials, to ensure they are prepared to commence elective outpatient services without increasing COVID-19 transmission risks. Additional guidance for later phases of re-opening (including inpatient elective surgery) are under development by CMS. EBG summarizes the current guidance as follows:

General Considerations

  • Coordinate with State and local public health officials
  • Prioritize services based on clinical need
  • Consider segregating Non-COVID Care (NCC) zones that would screen all patients for symptoms of COVID-19. Routinely screen staff and workforce
  • Sufficient resources available to the facility across phases of care, including PPE, healthy workforce, facilities, supplies, testing capacity, and post-acute care, without jeopardizing surge capacity

Personal Protective Equipment

  • CMS/CDC recommendation that providers and staff wear surgical facemasks at all times, including N95 masks and face shields as appropriate
  • Patients should wear a cloth face covering

Workforce Availability

  • Staff should be routinely screened for symptoms of COVID -19 and if symptomatic, they should be tested and quarantined.
  • Segregate staff working in COVID care zones and NCC zones
  • Community staffing levels must remain adequate to cover a potential surge

Facility Considerations

  • In a region with a current low incidence rate, the facility should create NCC zones
  • Administrative and engineering controls should be established to facilitate social distancing
  • Visitors should be prohibited unless necessary for an aspect of patient care, they should be pre-screened in the same way as patients.

Sanitation Protocols

  • Thorough cleaning and disinfection prior to using spaces or facilities for patients with non-COVID-19 care needs
  • Ensure that equipment such as anesthesia machines used for COVID-19 (+) patients are thoroughly decontaminated


  • Adequate supplies of equipment, medication and supplies must be ensured, and not detract for the community 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.
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