Late last week, the federal government released guidelines, Opening Up American Again, establishing three phases for reopening the economy. With respect to ambulatory surgery centers’ concerns, the policy suggests that, once a state or region meets certain gating criteria, elective surgeries can resume, as clinically appropriate, on an outpatient basis.

On April 19, the Centers for Medicare and Medicaid Services (CMS) issued recommendations for Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare: Phase I. These guidelines focus on issues that should be of concern to providers considering re-opening their practices and facilities if states and localities so permit.

New CMS recommendations

The CMS recommendations aim to give healthcare facilities some flexibility in providing essential non-COVID-19 care to patients without symptoms of COVID-19 in regions with low incidence of COVID-19. The following are highlights:

  • In coordination with state and local public health officials, facilities should evaluate the incidence and trends for COVID-19 in their area.
  • Facilities should evaluate the necessity of the care based on clinical needs, prioritizing surgical/procedural care.
  • Facilities should consider establishing Non-COVID Care (NCC) zones that would screen all patients for COVID-19 symptoms, including temperature checks.
  • Healthcare providers and staff should wear surgical facemasks at all times and patients should wear a cloth face covering if they don’t possess surgical masks.
  • Staff should be routinely screened for symptoms of COVID-19 and if symptomatic, they should be tested and quarantined. Staff working in NCC zones should not rotate into COVID-19 care zones.
  • 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.
  • Sanitation protocols should be in place providing for cleaning and disinfection of the facility and decontamination of anesthesia equipment pursuant to CDC guidelines.
  • Adequate supplies of equipment, medication and supplies must be ensured and not detract from the community’s ability to respond to a potential surge.
  • All patients must be screened for potential symptoms of COVID-19 prior to entering the facility.
  • When adequate testing capability is established, patients should be screened by laboratory testing before care and staff should be regularly screened by lab test as well.

Should you have any questions, please contact OOSS Washington Counsel, Michael Romansky at or OOSS Executive Director Diane Blanck at

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