PA Dental Practices Permitted To Re-Open For Routine Cleanings

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On June 3, 2020, the Pennsylvania Department of Health (DOH) issued revised Guidance permitting dental practices to re-open for non-urgent and non-emergent care, including, but not limited to, routine cleanings.  Dentists around the State have been awaiting this green light from the DOH, as it has been difficult for practices to re-open without being able to perform routine cleanings.

The Guidance is effective immediately, and requires dentists to apply their clinical judgment and a Care Framework, based on the CDC’s Guidance on Providing Non-COVID-19 Clinical Care during the COVID-19 Pandemic, when deciding whether to re-open their practices and treat certain patients.

The Framework is set forth on page 3 of the DOH Guidance, and breaks down the possible scenarios of treatment based on (1) the degree of patient harm if care was deferred, and (2) the extent of COVID-19 transmission in the practice’s community.  Of note, for those patients at the least risk of harm for deferring care in areas with moderate transmission of COVID-19, practices are to prioritize the patients who need care or those who would be more likely to be harmed by continuing deferral of care.  This guidance grants practices the latitude necessary to perform routine cleanings on prioritized patients in such communities.

As expected, the DOH Guidance recommends that practices comply with the CDC Interim Infection Prevention and Control Guidance for Dental Settings During the COVID-19 Response when delivering care to patients in communities experiencing minimal, moderate or substantial community transmission of COVID-19.  The Guidance also directs dentists to continue to practice universal source control, actively screen for fever and symptoms of COVID-19 with each patient and employee, and use appropriate PPE in accordance with CDC Guidance.   The DOH Guidance also offers a link to the PA COVID-19 PPE Interchange Directory to help dental practices obtain necessary PPE.

Pre-screening patients prior to an appointment and screening patients and employees upon arrival at the practice are critical to complying with a dentist’s standard of care in the wake of the COVID-19 pandemic.  Fox Rothschild is assisting practices in preparing appropriate patient and employee screening documentation and policies to document adherence to that standard of care, as well as other matters related to re-opening.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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