The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
Episode #43 CDC February 2, 2022 Updates for Healthcare
Use Left/Right to seek, Home/End to jump to start or end. Hold shift to jump forward or backward.
In keeping abreast of the ongoing COVID-19 changes, the CDC updated its Interim Guidelines for Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 Pandemic. Listen to this episode to learn what's new and what we should still be doing in our practices.
Welcome. I'm Leslie Cannon. I'm Mary Gavoni.
SPEAKER_01I'm Linda Harvey. I'm Olivia Juan, and together we are the Compliance Divas.
SPEAKER_03Hello and welcome to this episode of the Compliance Divas Podcast. My name is Linda Harvey, and I will be your moderator today. We bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please subscribe to the ComplianceDivas Podcast through your favorite podcast channel or on our website, thecompliancedevas.com. Any resources that we mentioned during this podcast can be found on the compliancedevas.com website. And we invite you to submit your questions to support at thecompliancedeivas.com. I think we all agree that nothing has been sure for the past two years at all. The time has been filled with many challenges, unknowns, and constant changes. One of those constant changes has been keeping up with the CDC interim guidelines related to SARS-CoV-2. And at times it's been challenging because teams often confuse the CDC guidelines for schools or the general public with those guidelines for healthcare. Today the Divas are going to discuss the February 2nd updated CDC guidelines for infection prevention and control recommendations for healthcare personnel during the coronavirus disease. So this podcast is current as of February 14th, 2022. Mary, can you please kick us off with uh talking to our listeners about do they still have to conduct screenings and why?
SPEAKER_02Linda, I think this is such a timely topic because we're hearing on the news about the number of Omicron cases declining and about the um mask mandates being lifted in many states and local areas, including in many schools, but those apply to public buildings. Those do not apply to healthcare settings. And so the the CDC guidance that was updated on February 2nd is very specific about making sure that we have a process to identify and manage individuals who either are suspected of having COVID-19 or have a confirmed case of COVID-19. And even though these screenings procedures, which are described in the CDC guidance, don't specifically say taking temperatures, that is part of identifying people with symptoms. So this guidance, which we will make available in our resources for the podcast, says that we need to make sure that everyone in our facility is aware of the infection prevention and control practices. And that's using signs and posters. And the CDC has a number of them available that facilities can use, which we'll also give you the links to in our resources, and having a specific process to identify anyone entering the facility regardless of their vaccine status. And remember that up to date is the current term that's used. Now, up-to-date means you've had either one injection of the Johnson Johnson vaccine plus a booster, or you've had two injections of the Moderna or the Pfizer vaccine plus a booster. So anyone coming into our facility, whether it's an employee or whether it's a patient, if they've had a positive test for SARS-CoV-2, should not be there. That's part of the screening. Anyone who has symptoms, and so respiratory symptoms, a fever, any of the symptoms that are listed by the CDC is indicative of COVID-19, or someone who's had close contact with someone with COVID-19 infections, and that means patients, visitors, employees, or someone who's at a higher risk of exposure, meaning a healthcare provider. So while the mask mandates may be being relaxed, that does not mean that that's a signal to us in dental health care settings to stop the screening process.
SPEAKER_03Thank you, Mary. That dovetails so nicely into what we know the OSHA laws and the OSHA guidance talks about as well. And I think our teams have gotten a little weary with doing this, but it's important, as you mentioned, to recognize that we are not the general public in a healthcare setting. And in particular in dentistry, with aerosol generating procedures, we do have to be very cautious and follow the guidelines. Olivia, could you talk to us for a minute about what the CDC says with source control measures? You know, Mary just enlightened us that we still should be screening. So is that another area that we should still be following as well?
SPEAKER_01Sure, Linda. CDC confirms that the source control options in a healthcare facility would include the NIOSH approved N95 or equivalent, uh, also respirators such as a KN95 or a well-fitting face max. But they make it very clear, Linda, in the guidance that if healthcare personnel are using they're using uh a respirator for care of the patient, where it's personal protective equipment, it has to be a NIOSH-approved respirator. So once again, we cannot use the KN95 for respiratory protection when serving a patient clinically. However, those three options, N95 or KN95 or well-fitting face mask, is fine for source control. So in my mind, I'm thinking like an administrative personnel member would be appropriate to make one of these choices. So what we don't want to see in a dental office would be cloth mask. And I know people have their favorite decorative cloth masks that match their outfits or the season or their football team, but they should not be wearing cloth in a dental facility.
SPEAKER_03Thank you, Olivia. That really helps to distinguish the fact that we still should be wearing source control masks within the practice. And interesting, I think many times patients get frustrated with that piece. They don't want to be screened and they don't want to wear source masks themselves because they liken it to different processes that are happening in medical offices. I think dentistry is not the only group that's confused with a lot of the guidelines, and there's conflicting measures throughout healthcare when we are doing our best in dentistry to really stay as safe as possible, especially since we are producing aerosol-generating procedures. Leslie, can I ask you to please elaborate more on the mask and the use of universal PPE for healthcare providers and just kind of reiterate where we are with the KN95 mask, if you don't mind?
SPEAKER_00Certainly, Linda. When we talk about implementing universal use of personal protective equipment for healthcare providers, we need to make sure that we understand the difference really between standard precautions, which is basic practices that apply to all patient care, and then transmission-based precautions. And those are additional precautions when we have either patients with documented or suspected diagnoses where contact with that patient, their fluids, or uh any other of their environmental surfaces that they have touched presents a substantial transmission uh risk despite adherence to standard precautions. So, what CDC is telling us in this new guidance is that healthcare providers who are working in counties with substantial or high transmission should use PPE as follows. And what they said is NIASH-approved N95s or equivalent or higher respirators should be used. Now, uh going forward, I'm going to say N95s, and you'll know that I mean uh equivalent or higher, but N95s should be used for all aerosol generating procedures, and then all surgical procedures that might pose higher risk for transmission, and this is if the patient has a COVID infection. And then also NIOSH uh approved N95 or equivalent uh should be used by healthcare workers in other situations when there's additional risk factors for transmission. And that might be present. For example, if the patient is not up to date with all recommended COVID-19 vaccine doses, uh the patient is unable to use source control, which is certainly the case in dentistry, and the area is poorly ventilated, which can also sometimes be the case in dentistry, especially with the vegetable-style uh dental treatment rooms or operatories. And so what CDC is recommended is just to simplify implementation, counties where there's high or substantial transmission should consider implementing what's called universal use of N95s for healthcare workers during all patient care encounters. And so that would something be something I think that we could keep in mind rather than trying to decide uh between all these other factors, if we just simply implement a strategy of wearing N95s going forward, it would be the best step. Another part of the PPE universal precautions would be goggles or face shields. So no longer safety glasses where there could be aerosols that could reach the eyes of the dental worker, but goggles or face shields should be worn during all patient care encounters. Now, I think one other point uh that just to just to put a little spin on what Olivia was saying with the uh CAN 95s, so of course the CAN 95s are not appropriate for uh protection, for respiratory protection for healthcare providers, but the general public, of course, is being given guidance to get uh the best-fitting type of uh mask that they will wear consistently. And if they can get a CAN 95, that is uh more appropriate than uh seeking out the surgical N95s to try to reserve those for healthcare providers. Linda.
SPEAKER_03Thank you, Alessie. Those are some very important points at this point. No pun intended here, but the use of N95 respirators is the best mask for all procedures, especially in light of the fact that um pretty almost every area of this country is in the red zone still with the number of COVID cases. When I looked at the CDC tracker update the end of last week, I could identify maybe a handful of counties that weren't. And they were in very isolated areas like um North Dakota, South Dakota, Nebraska, and I think a few counties in Texas that I particularly remember. So having use of an N95 respirator for all procedures really makes common sense right now, versus trying to think, is this aerosol, is this not aerosol, what do I wear? And then I'd like to dovetail on your points about standard precautions and transmission-based precautions. We all saw in the OSHA guidance for managing SARS-CoV-2 that that's what we should be implementing. And of course, we all know that that's the CDC writes those guidelines, not OSHA. So OSHA is essentially telling us that they are going to be enforcing the CDC guidelines when there's any type of complaint or unannounced inspection. Dentistry has not been, let's see, what's the word I want to use? Dentistry has is still in the high risk category for SARS-CoV-2 under the OSHA guidance. So that has not changed. So we still have to be mindful of what's happening, even though I'm thrilled to hear that the numbers are coming down a bit now. We're still not out of the danger zone, so to speak, until we kind of see what happens next and how everything levels out. It's not going to end immediately. Um, Leslie, go ahead.
SPEAKER_00You know, I think our listeners should be reminded that back as far as May of 2021, N95s have been readily available and there's plenty of domestic supply. So if thinking that maybe we can't get N95s is how we might strategize whether to use them or not, know that they're widely available now.
SPEAKER_02Mary, you had a comment as well. I did. Thanks, Linda. Um, and as you said, we we see those isolated areas where there is less risk of spread of Omicron, which are probably parts of the country where there aren't a lot of people. So in highly populated areas, we still see those cases. But keep in mind what's lurking in the background, which we still don't know a lot about yet, is the BA2 variant of the Omicron variant of the ancestral virus. So we still don't know a lot about it, but it has been identified in the US. So we have to keep that in mind as well.
SPEAKER_03Thank you, Mary. Yes. Um SARS-CoV-2 is an ever-changing virus and it's going to be around for years to come, forever. We just have to see um how everything plays out with the next variations and what they all mean. Olivia, I'd like to circle back to you for just a minute and let's talk for a second about engineering controls and the indoor air quality. So when we think about we're going to be wearing this appropriate PPE, we're screening our patients and using source control measures, but what else can we do in that environmental area? What is the CDC recommending now?
SPEAKER_01Sure, Linda. When we look at the guidance, uh keep in mind that these recommendations were published for healthcare personnel. So we need to look for the section under dental facilities. And in that grouping, CDC makes the recommendation to utilize these portable HEPA air filtration systems. And interestingly, I've been polling my audiences and asking them during seminars and workshops, you know, how many dental offices have implemented HEPA air filtration or other type of engineering control? And unfortunately, it's been about 30%. So we would like to see those numbers to increase because this is a CDC recommendation that we enhance the effectiveness of the portable HEPA air filtration. And also for open floor plans, make sure that the chairs are six feet apart and consider utilizing physical barriers between the chairs. Now, Linda, I actually have a client uh that installed uh walls between the chairs, it was a completely open concept orthopedo practice, and they followed the guidelines. They took this very seriously, and the they installed these walls, and it's actually really nice because it gave it not only the compliance of this guidance, it gives it more privacy for the patients uh in the rooms. So we want to make sure we're following this section in minimizing the aerosol that's present in the offices and been encouraging people make sure if you have these engineering controls implemented, to be sure to write it into their hazard assessment and document that they've implemented that into that section because OSHA would want to see what they are doing. I know when I spoke to an OSHA inspector recently, he compared COVID to Swiss cheese, having all these holes in the cheese, and it's multiple layers of approaching protection, respiratory protection in multiple different ways. So, not only with your PPE would we protect our workplace, but also installing these engineering controls, such as the HEPA filtration. So I hope that helps our listeners to uh align themselves with the guidance in this particular section and not to forget of checking in with their local uh dental board to see if there's any additional recommendations.
SPEAKER_03Thank you, Olivia. Those are some extremely important reminders. And I especially uh like the analogy that Ocean Inspector used about Swiss cheese. I've seen that analogy used many times over the years related to patient safety. And it's it's a perfect example. We have to have multiple layers of protection. And for offices that aren't sure or didn't know or they should be wearing the N95 mask or dropped off on using source control measures. If there's some kind of complaint or if uh COVID has spread in their practice and an employee ends up in the hospital, that's reportable to OSHA. And as soon as I say that to any audiences, I can just see everybody rolling their eyes because you know, how are you going to prove it happened here? I have a screenshot of my team member who was on a party last Friday night and posted it on Facebook. So obviously those things aside, but if you have an outbreak of COVID in your practice, then it's going to become more clear that this is where everybody's trends, contracting COVID. And especially if you don't have the documentation to prove that you've provided a workplace that's free, relatively free from known hazards, as is required by OSHA's general duty clause. Then just like with patient records, if it's not written down, it didn't happen, and the office is going to stand to lose and end up with a big fine at best. So thank you, Livy. Those are some very important reminders. Mary, let's wrap it up and talk a little about the SARS-CoV-2 viral testing and what's going on with that area, please.
SPEAKER_02Thanks, Linda. One of the most important things that I tell all the people that I work with about SARS-CoV-2 testing at this point is that if you have symptoms, even mild symptoms, whether you are a member of the general public or especially if you're a healthcare worker, you need to get tested. Whether you are up to date on your vaccines or whether you are non-vaccinated, it doesn't matter because, as we've talked about throughout this podcast, the more variants we see and the more spread of SARS-CoV-2 that we see, the more potential there are for new variants, for more spread, and the cases are still high. Even though we're tired of it, we see the cases starting to come down. So if you have symptoms, get tested. Now, in some areas of the country, we've heard that it's a challenge to get tested, or you know, they can't get the home testing and so forth. But there are very specific guidelines from the CDC, and we will put that um set of guidelines in the resources. And the guidelines um have to do with testing for SARS-CoV-2. And then there's another set of guidelines that's interim guidance for managing healthcare personnel with SARS-CoV-2 or exposure to SARS-CoV-2, because this information has evolved over the last six months or so about work restrictions and when can you return to work? And do you have to have a one or a two-step strategy? So I encourage everyone to make sure that they do have a written process. What do we do if one of our team members is identified as COVID positive or they've indicated that they've had a significant exposure? What is our step-by-step protocol for making sure that we're not putting others at risk? And the CDC has spelled that out for us perfectly in these two sets of guidelines for us.
SPEAKER_03That's perfect, Mary. I think the points you raise are so timely with how do we look at the process for responding to exposures among team members. Officers are confused as we began the program and stating that there's just been nothing but change and challenges the past two years. And that piece is going to continue with the evolution and mutation of the SARS-CoV-2 virus. So I mean currently we definitely encourage all of our listeners to download the today's resources. So if you don't have a current copy of the February 2nd updated guidelines in your office, you can certainly have that, and then begin to go through the different aspects that we've discussed today. Some of the things that we've talked about in today's podcast are reminders of what was already in place with the CDC, and there's been some small changes that we still have to keep abreast of. And importantly, to remind everyone that we just should not be dropping our protocols because we feel like some cases have come down or we're weary of the protocol. This is the new standard in dentistry. So going forward, we will see this become, this is our norm. So it's about bouncing forward with the changes and keeping up with the um the updates and moving forward in a safe and healthy manner. So we thank you for joining us in today's podcast. The compliance divas bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. Please submit your questions to the support at the compliance divas.com. And don't forget to visit our website, thecompliancedevas.com, where you can download today's resources. See you next time.