Phase 1

Updated 5/26/20

On May 18, Governor Baker announced the results of the Reopening Advisory Board’s report regarding the phased reopening of the state. During the Reopening Advisory Board’s stakeholder meetings, Massachusetts Dental Society (MDS) representatives presented information on how dental facilities could safely and slowly begin expanding care. The first phase, which is currently expected to begin Monday, May 25, includes an increase in allowable dental procedures for those providers who are able to meet key public health criteria as set by the Provider Advisory Committee.  

The beginning of Phase 1 hinges on the overall management of the COVID-19 pandemic. This has been the primary focus for the governor and the state’s COVID-19 Response Command Center. In order to move into Phase 1, it is critical that the state maintain greater than 30% capacity of ICUs. The state has been unable to move into a phased reopening because this and other critical benchmarks have remained elusive until recently. As the governor noted, if the data begin to show a backwards trend, it is possible that care will again become limited to emergencies only.  

In order to prepare providers for Phase 1 as the state approached the key ICU benchmark, the Reopening Advisory Board formed a Provider Advisory Committee comprised of key provider groups, including representatives from the MDS. The Provider Advisory Committee was tasked with outlining necessary criteria and guidelines to enable non-hospital-based providers to open. Individual providers must meet the following criteria prior to beginning Phase 1 services: 

  • Have current adequate supply of PPE and maintain adequate supply on an ongoing basis without support from the state stockpile 
  • Meet public health and safety standards in the domains of workforce safety, patient safety, and infection control 
  • Designate a compliance leader at the highest level of the organization 
  • Attest to and maintain the attestation form acknowledging that they meet all of the requirements in PPE, health and safety standards, and compliance standards (practices must retain this attestation for inspection upon request by the Department of Public Health)
     

When Phase 1 begins, dental practices will be able to treat patients with emergent or likely to become emergent if care is deferred symptoms. Dental practices should continue only treating emergency and urgent care patients until Phase 1 begins. In preparation for this expansion of dental treatment, the MDS, in collaboration with leaders of each of the Massachusetts specialty organizations, has created a resource document to assist providers in identifying situations that are likely to become emergent if care is deferred. Ultimately, providers must use their own clinical judgment in determining which procedures for which patients may continue being deferred during Phase 1. 

Dentists are expected to use their professional judgment to provide emergent and likely to become emergent if deferred care within parameters set forth by the state. It is up to the doctor to determine that treatment is emergent or likely to become emergent. Dentists have well-trained professional judgment. The MDS is here only to offer broad guidance and point to official state guidelines. Any dentist providing care during Phase 1 should consider documenting in the clinical record why the treatment being prescribed during the phase is not simply routine or elective care and record your Centers for Disease Control and Prevention (CDC) compliant protocols and PPE usage.

We understand this can be a confusing time for staff and patients. Again, the dentist, as the leader of the dental team, is best positioned to assure staff and patients that the work being done is appropriate under the current guidelines and that the dental team is strong, compliant, and following all safety measures.

The MDS has compiled the following questions and answers to offer general guidance to members. You should continue to rely on your best professional judgment. We will continue to update this section as more information becomes available or as information changes.

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Situations that are likely to become emergent if care is deferred

When does Phase 1 of the governor’s plan begin?

Does the Phase 1 date vary for areas of the state less impacted by COVID-19?

How long is Phase 1?

What are the goals of Phase 1?

What is the Phase 1 start date tied to?

Why is dentistry tied to statewide hospital capacity data?

What is meant by emergent care?

Is there a list of emergent care services for dentists in Massachusetts to follow?

Why is the recommendation coming out so late?

What kind of care can I offer my patients?

What are the reopening criteria?

Where does hygiene fit into the governor’s Phase 1 reopening?

What is required of me in order to be able to begin Phase 1 care?

What if my office does not have sufficient PPE?

The CDC’s current interim guidelines say that dental offices should continue to delay all elective care and only treat emergencies and urgent care. Why is the MDS offering different guidance?

What are the required public health criteria and safety standards for the dental practice?

What are the required public health criteria for safety standards for patient safety?

What are the required public health criteria for safety standards on infection control?

Do practices need to appoint a compliance officer to manage the public health criteria?

Who has the authority to monitor and assess compliance with public health criteria?

What staff should I bring back to work?

Is it possible that we will move into Phase 1 and have a setback that requires us to revert back to emergency care only?

What should I do if I have already recalled routine appointments?

Is the May 25, 2020, Phase 1 start date subject to change?

What are the benchmarks for moving to Phase 2 of Reopening?

Can I bill patients for PPE expense?

What are the waiting room requirements?

Do I need to have a written protocol on how I am screening employees for COVID-19?

Do I need to have a written protocol on how I am screening patients and their companions for COVID-19?

Can I limit patients from bringing companions with them to appointments?

Are patients required to wear face masks?

Are there signage requirements in place on social restrictions?

Do I need to have hand sanitizer available to patients and staff?

Do I need to put together a plan for cleaning and disinfecting my office?

What Facility Considerations Does the CDC Recommend?

What Are the CDC Equipment Considerations for Reopening?

What Engineering Controls Does the CDC Recommend?

What Does CDC Recommend for Patient Placement?

What Patient Volume Does the CDC Recommend?

How Long Do I Need to Wait to Disinfect a Room Between Patients?

When Does a Face Mask Need to Be Worn by a DHCP?

Are Cloth Face Coverings Acceptable for DHCPs?

Do Non-Clinical Staff Need to Wear Face Mask in the Office?

Can a Cloth Face Mask Be Substituted for a Surgical Mask During Clinical Procedures?

What PPE Is Required for Procedures Likely to Generate Splashing or Spattering of Blood or Other Body Fluids?

What Are the Donning and Doffing Requirements for PPE?

Is There an Alternative to N95 Respirators for Aerosol-Generating Procedures Conducted on Patients Assumed to Be Non-Contagious?

Do I need to close my office if a patient or employee tests positive for COVID-19?

Resources

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