March 13, 2020
TO: UltraGroup Program Directors/Medical Directors
FROM: Kelly E. McBryde & Karen A. Fauer
RE: Coronavirus (COVID-19)
UltraGroup would like to provide you with some guidelines and recommendations with regards to your duties as Program Directors of the IOP, Inpatient, & Medical Stabilization programs as follows:
UltraGroup’s current recommendations for programs related to COVID-19: based off of CDC recommendations found here https://www.cdc.gov/coronavirus/2019-ncov/about/prevention.html
Intensive Outpatient Programs:
We strongly recommend that you work directly with your hospital’s Infection Preventions to comply with any hospital wide policy or procedure.
COVID-19 is a virus transmitted by people in close contact with one another (generally 6 feet or less) and is spread through droplet transmission such as coughing or sneezing. Clients should be told to stay home if they have a fever, cough, or sneezing. Try to keep as much space between clients in the group room as possible.
Clients should have their temperatures taken upon arrival prior to entering the group room (if possible). Any client with a temperature should be sent home immediately.
Clients should be encouraged to wash their hands often with soap and water for at least 20 seconds (singing Happy Birthday twice is a good way to take up 20 seconds). Have alcohol-based hand sanitizer available, in an area that is monitored by staff, for times when clients cannot immediately wash their hands.
Remind clients to cover their coughs and sneezes by coughing or sneezing into their elbows not their hands.
If clients do use a tissue direct them to throw it in the trash immediately. They should not keep reusable tissues in their pockets or purses.
Remind clients to refrain from touching their eyes, nose and/or mouths.
Clean surfaces in the programs frequently (i.e. prior to client arrival, in between group sessions, after lunch, after clients leave) with hospital approved wipes or cleansers ex- Lysol or Clorox wipes, Sani Wipes, etc.
We recommend suspending handshakes and/or hugging when greeting or saying goodbye to clients until the virus has stopped spreading and/or is under control.
In the event that a current client is living in a facility that has determined to self-quarantine (i.e. the local nursing home) we recommend an Abrupt discharge according to policy 02.11.04. This policy indicates the program staff will continue to reach out and follow up with client until such a time as readmission is warranted.
Several programs have asked good questions regarding client screening, reduction of services, or potential program closures. We have reached out to our legal consult for additional guidance as you and your hospitals make these determinations. Answers to a few of those specific questions are below.
If need be, for patient safety, can we allow our patients to stay home and have our IOPs do individual therapy from the program site by telepsych? And if they are not set up with telepsych software, can they just counsel by phone? If so…. can the hospital bill for any of this?
The IOP may provide services through telepsych or over the phone, but under Medicare’s regulations, the hospital would not be able to bill for any of these services. The Medicare Benefit Policy Manual, Chapter 6, Section 20.5.2 is clear that for services to be covered as hospital outpatient therapeutic services, the services and supplies must be furnished in the hospital or at a department of the hospital. "In the hospital" means areas in the main building(s) of the hospital that are under the ownership, financial, and administrative control of the hospital; that are operated as part of the hospital; and for which the hospital bills the services furnished under the hospital’s CMS Certification Number. Therefore, services in a patient’s home would not be covered.
2. Can they refuse to allow patients with coughs, etc. in the program?
While the program may turn away or refuse service to patients, this does present a potential public relations and patient abandonment malpractice issue. A patient could potentially make the claim that the practitioner terminated the practitioner-patient relationship without reasonable notice or a reasonable excuse, and failed to provide the patient with an opportunity to find a qualified replacement care provider. Although the hospital could argue there was a “reasonable excuse,” a cough alone may not be enough to meet this standard. Further, with the intense media focus on COVID-19, this could result in negative press if a patient is turned away from the program—especially if they later test negative. Instead, we would suggest a uniform screening of all patients, regardless of symptoms. If the patient’s symptoms do warrant prohibiting outpatient therapy, the hospital should provide the patient with a reasonable opportunity to find replacement care or may consider providing telehealth coverage.
3. Since they are IOPs, can the hospital temporarily shut them down, or would it be a problem to stop treatment?
There is no Medicare regulation or guidance that would prohibit the hospital from temporarily suspending the IOP service. However, there are likely state-specific licensure and CON regulations that would require notice to the corresponding state agencies. If you have a particular hospital that is planning to suspend services, we are happy to analyze the regulations in that state. If you do close the service, to avoid any patient abandonment issues, you may consider providing telepsych services and daily check-ins, but please understand that the hospital will not be able to bill for these services.
Inpatient & Medical Stabilization Units:
1. We strongly recommend that you work directly with your hospital’s Infection Preventionist to comply with any hospital wide policy or procedure.
2. We recommend routine screening of patients, as determined by the hospital, for all inpatients.
3. Many hospitals are considering limiting or discontinuing visitation at this time to protect the health of all inpatients including those that may be in the age range to increase risk or have additional medical issues that would increase risk. Any determination of this type should be discussed with the broader treatment team and hospital administration for approval.
Should there be any changes to this plan or any new information that we need to share and/or implement, we will keep you informed. Thank you for your hard work during these times. We will continue to monitor this situation as warranted.