On March 18, CMS issued a series of recommendations regarding the furnishing of all non-essential planned surgeries and procedures based on the need to conserve critical resources, such as ventilators and Personal Protective Equipment, and limiting exposure of patients and staff to COVID-19.

The agency provided a tiered format of guidelines (CMS Guidelines) to inform health systems as they consider resources and how best to provide surgical services and procedures to those whose condition requires emergent or urgent attention “to save a life, preserve organ function, and avoid further harms from underlying condition or disease.” CMS identified cataract surgery as an example of “low acuity/healthy patient” as outpatient surgery that doesn’t encompass a life threatening illness.

These recommendations are not mandates. CMS states that “decisions remain the responsibility of local healthcare delivery systems, including state and local health officials, and those surgeons who have direct responsibility to their patients. However, in analyzing the risk and benefit of any planned procedure, not only must the clinical situation be evaluated, but resource conservation must also be considered.” Recommendations will be refined over the duration of the pandemic.

CMS Guidelines

We urge OOSS members to seriously consider these recommendations for non-essential planned surgeries and the guidelines below that have been developed by medical specialty organizations and others.

American Academy of Ophthalmology
Ambulatory Surgery Centers Association
American Medical Association
American College of Surgeons
American Hospital Association
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Should you have any questions, please contact our Washington Counsel, Michael Romansky, JD at or our Executive Director, Diane Blanck at

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