Phasing in Reopening Your Practice

As physician offices are re-opening during the COVID-19 pandemic, there are questions and concerns about how to do so safely. This article is meant to provide ongoing support and risk management recommendations in addition to the previous Psychiatric News article on the nuts and bolts of reopening your practice, including obtaining consent from the patient returning to the office.

First and foremost, continue to follow the Centers for Disease Control and Prevention guidelines on social distancing, masks, and hand hygiene and your state and local restrictions. Take into consideration your health and that of your patients and whether to continue with telepsychiatry, reopen your practice to see patients in person, or have a hybrid practice (seeing select patients in person but continuing telemedicine sessions, especially with medically compromised patients or patients who take mass transit to travel to your office).

Be sure your office has masks for you, your staff, and your patients as well as an adequate supply of hand sanitizer. Demonstrate use of both, including using the hand sanitizer when your patient enters the session room. Avoid shaking hands with your patient and explain why.

Reorganize your office to allow for physical distancing, especially if you remove your mask to better interact with your patient. Try to avoid more than one patient in the office at a time, and allow enough time between patients to wipe down surfaces.

Questions on our Helpline have included whether sessions can be conducted at a public park or other public area. This decision needs to be made cautiously, with explicit arrangements made to address auditory and visual confidentiality and with written patient consent.

Consider the option of continuing with telepsychiatry services in the states where your patients are residing. Among the factors to consider are whether colleges and universities have reopened to on-campus education or students are splitting their time on campus and online; when and to what degree the state governors will be rescinding their executive orders, especially regarding licensure; and when the Drug Enforcement Administration resumes compliance with the Ryan Haight Act, which requires health care professionals to conduct an initial, in-person examination of a patient before electronically prescribing a controlled substance.

If you decide to continue with interstate telepsychiatry, initiate the application for permanent licensure in the relevant states where your patients are located. Check the status of COVID-19 state guidelines on APA’s website.

The Interstate Medical Licensure Compact (IMLC) is an agreement that allows states to work together to significantly streamline the licensing process for physicians who want to practice in multiple states. Information, including eligibility requirements, on the IMLC is posted here. Of note, the State of Principal License, which is the state in which a physician holds a full and unrestricted medical license, must be a full and unrestricted medical license in a state currently participating in the IMLC.

Continuing with telehealth requires a HIPAA-compliant platform with a Business Associate Agreement to ensure your protection in case of a data breach. Psychiatrists should enable all available encryption and privacy modes when using all telehealth modalities.

Continue to ensure patient screening, both for in-person and telepsychiatry sessions. Ensure compliance with the standard of care, which is the same whether care is provided in person or via telemedicine.

When making reopening decisions, be sure to consider the appropriateness and safety of care whether provided in person or via telepsychiatry services. Safety for your patients and for yourself is paramount, now more than ever. ■

This information is provided as a risk management resource for Allied World policyholders and should not be construed as legal or clinical advice. This material may not be reproduced or distributed without the express, written permission of Allied World Assurance Company Holdings, Ltd, a Fairfax company (“Allied World”). Risk management services are provided by or arranged through AWAC Services Company, a member company of Allied World. © 2020 Allied World Assurance Company Holdings, Ltd. All Rights Reserved.