[co-author: Michael Lisitano]*
On May 17, 2020 Connecticu]t Governor Ned Lamont – in conjunction with the Department of Public Health (DPH) – released a guidance document for resuming non-emergency dental procedures (the “Guidance”). The Guidance notes that while dental practices were never subject to an executive order to close, the governor’s office and DPH had both strongly encouraged the suspension of all elective procedures and routine non-emergency care. Accordingly, as certain businesses in the state begin to reopen starting on May 20th, the Guidance is designed to inform dental practitioners on preparation and policies for expanding services beyond emergency-only care to include elective procedures and routine hygiene and health exams. The document details policies for expanding offered procedures and notes that dental practices that cannot meet the guidelines “are strongly advised to delay expansion of their operations beyond urgent care until they are able to meet these guidelines.”
According to the governor’s office and DPH, the guidelines are a minimum baseline to protect employee, patient, and public health. These guidelines are divided into six categories:
- Planning and Preparation: including, but not limited to, informing employees of COVID-19 policies, developing cleaning plans, and creating logging protocols to facilitate contact tracing.
- Physical Space Setup: including, but not limited to, social distancing markers, individualized workspaces, and waiting room modifications.
- Health Screening: including, but not limited to, symptom checking of employees and logged touchless temperature checks upon reporting to work, as well as pre-appointment phone screenings of patients and temperature checks upon arriving for appointments.
- Work Practice Controls: including, but not limited to, more time allotted for procedures to allow for expanded cleaning protocols and a minimum of one hour for performing aerosol-generating procedures within each procedure space and at least an additional 30 minutes of dedicated time for sanitizing.
- Personal Protective Equipment (PPE): including, but not limited to, ensuring the availability of appropriate PPE as required by the types of procedures being performed.
- Cleaning and Disinfecting: including, but not limited to, policies and practices for cleaning examination rooms, equipment and common touch surfaces.
The Guidance also reminds dentists of their obligations to comply with Centers for Disease Control and Prevention (CDC) guidelines for infection control in dental care settings and all Occupational Health and Safety Administration (OSHA) requirements for safe workplaces. In addition to reviewing the Connecticut Guidance, the document recommends dentists review “the most current guidance from CDC, the Connecticut Department of Public Health, [OSHA], and their professional organizations and check frequently for updates to guidance documents from those organizations as well as the recommendations detailed in” the Guidance.
*Legal Intern at Robinson+Cole. Michael is not yet admitted to practice law.