As a mutual company, CMIC RRG is here to support our members throughout this crisis however we can. These are challenging and unprecedented times, and as a company, our primary focus is helping our members through this so they can focus on their health, and the health of their patients. Please feel free to reach out to us at any time with questions about coverage, best practices, or anything else we may be able to assist with. We are here for you, and we will all get through this together.
Below please find COVID-19 information and resources, as well as a list of Frequently Asked Questions. Our intention is to update this regularly so please reach out to us if there is something you would like more information on, or anything you would like to see added.
Documentation Update Focusing on Delayed Procedures Due to the COVID-19 pandemic many elective surgeries and non-emergent medical procedures are being postponed and patients may be delaying various procedures and tests. In the event that a provider has had a patient who postponed a surgical or diagnostic procedure or clinical labs, documentation of the length and reason for the delayed event is important.
In regards to routine surveillance procedures such as yearly eye exams or a once-every-5 year colonoscopies, documentation is still recommended in terms of rescheduling. If the patient had the surgery postponed due to the pandemic, but was hospitalized and needed emergent surgery, accurate and precise documentation in this scenario would be favorable.
Equally as important, if delaying a procedure or test carries a risk that a patient’s known medical condition may worsen, the provider should document that the procedure or test was unavoidably delayed and that the patient was advised about maintaining vigilance for and reporting to the provider about any changes in condition that would indicate disease progression.
Accurate and timely documentation is beneficial, especially when attempting to recall specific conversations or incidents that took place days, months or years prior to possible litigation. It is acceptable to write an addendum, however, it is more favorable to document in real time.
In the midst of the COVID pandemic, many individuals are hesitant to seek medical care when necessary. Emergency room visits have decreased by approximately 40% across Connecticut. This indicates that individuals may be reluctant to seek care when needed due to the fear of contracting coronavirus, out of respect to social distancing recommendations, or in an attempt to avoid overcrowded hospitals. However, you should encourage your patients to seek medical care in an emergency situation or when they feel it may be necessary or prudent. Below, please find a form that you can send to your patients encouraging them to seek medical care when necessary. You may alter the form to fit your needs.
Social Distancing While in the Workplace:
*Please be sure to check with your particular state and local health departments for specific guidelines and requirements.Best Practices for Reopening Dental Offices - CT Criteria for Return to Work for Healthcare Personnel with Suspected or Confirmed COVID-19 Reopening Practice Guidelines from the AMA Roadmap for Resuming Elective Surgery after COVID-19 Pandemic Sample Informed Consent Policy - COVID-19
Telemedicine Information, Recommendations, and Consent Form Note: Please see our FAQ page for coverage information
outbreak response measures to help control the spread of the infection.
We are currently in a crisis that has resulted in abnormal circumstances and has launched the use of consumer audio and video chat applications normally noncompliant with the HIPAA Security Rule. Any communication applications use for telemedicine would require a Business Associate Agreement with the vendor.
Be prepared to use consumer audio and video chat applications to communicate with patients as needed during the COVID-19 health emergency.
For more information on this process, please click here.
Based on the current need for hand sanitizers, the FDA has published a policy that you can find on their website here.
This policy provides information on guidance to temporary compounding of certain alcohol based products for use during these emergent times.
Patients infected with the coronavirus (COVID-19 virus) often require inhaled bronchodilator medications (e.g., albuterol). It has been determined that the use of nebulizer therapy with bronchodilators for suspected and/or confirmed COVID-19 patients may not be safe. This is attributed to the generation of aerosols, which increases the risk that respiratory droplets will remain in the air and spread the virus.
To reduce this risk, the current recommendation is to utilize metered dose inhalers (MDI’s) to deliver the medication. This could cause concern that the supply of MDI’s will decrease to dangerously low levels, posing problems for patients in need of this medication as we continue through the pandemic. MDI canisters usually contain enough medication to last 2-4 weeks, while patients are often hospitalized for shorter periods, frequently leading to drug waste. Currently, hospitals are considering the best way to conserve MDI supplies, which include:
1. Ask patients to bring in their own prescribed MDI from home for use while hospitalized.
2. When an inpatient is prescribed an MDI by the pharmacy, it is immediately being labeled for home use, therefore the patient can take it home with them upon discharge.
3. Consider putting in place protocols for MDI usage, however, during the pandemic, this may require intense examination and analysis of procedures.To view the alert, please click here.
Documentation and communication are critical during this time. Adhering to proper documentation procedures, regardless of the modality, is essential in maintaining consistency and accuracy. Clinicians need to utilize their best clinical decision making processes, especially, if the patient issue/complaint may require an in-patient visit, but during this time, may not be recommended. Documentation of these type of situations can be beneficial in the event that there is a less than optimal outcome.Recommendations Include: Document all conversations with your patients whether it be in the EMR or paper charting Timely documentation is very important Documentation should include rationales and basis for your decisions regarding care Be sure to include any conversations with family related to care and decisions Document any information related to COVID-19 and rationales for treatment as well as the options and/or lack of options at this time Document the rescheduling of treatments/procedures and the ongoing plan of care during this time of COVID-19 Be sure to accurately document any limitations in examinations do to the risk of COVID-19 exposure If you utilize any resources such as the DPH websites for information, guidance, etc. it may be helpful to document this information Other Resources Airway Management of Patients with Suspected or Confirmed Diagnosis of COVID-19 Infection APRN Prescribing Practice Updates from the Commonwealth of Massachusetts Blanket Waivers of Section 1877(g) of the Social Security Act CDC Checklist for Healthcare Facilities CDC PPE Strategy CDC Website Clinical Alarms CMS Telemedicine Fact Sheet Information Families First Coronavirus Response Act Massachusetts Department of Public Health Post Exposure Protocol PPE Burn Rate Calculator Society of Critical Care Medicine State Government Activity Turning Moral Distress Into Moral Resilience During the COVID-19 Pandemic World Health Organization
What is CMIC RRG doing to help policyholders at this time?
In an effort to help support our policyholders through the challenges created by the COVID-19 outbreak, the Board of Directors has deferred premium payments for all members. The new due date for premium payments is June 30, 2020.
We are currently evaluating various special underwriting considerations in response to coverage questions from our insureds during this outbreak. Please continue to reach out to us with specific questions so we can best serve you and your needs through the challenges ahead.
CMIC RRG has a variety of trainings available 24/7 for providers and staff, such as HIPAA Compliance training modules, a sexual harassment training webinar, and state mandated CME courses that are available via enduring material downloads and online webinars. Please reach out to us for more details if you are interested in participating.
Currently, our policy form states that CMIC RRG will respond to claims arising from services within the “customary scope of the insured’s practice specialty or classification as described in their declarations.” In other words, while there is no specific exclusion for the practice of telemedicine, the policy does restrict coverage to services provided that are within the scope of a physician’s specialty. Further, CMIC RRG is currently monitoring the legislative changes regarding the delivery of Telehealth services in response to COVID-19. In the event that a claim is made against our policyholders serving in this capacity, CMIC RRG will offer coverage that is commensurate with the legislation, effective the date the legislation is passed.
CMIC RRG is working to accommodate many changes to how practices are operating due to this evolving crisis. Our underwriters have the ability to provide coverage based on your decisions and needs as a provider. Many of our insureds have inquired about Scope of Practice, Leave Of Absence, Retirement, and Part-Time status, among other topics, and CMIC RRG will continue to be able to provide you with coverage that meets your needs.
Please reach out to our Underwriting team so we can discuss your individual circumstances and craft a policy plan that works for you and your practice during these challenging times.
CMIC RRG greatly appreciates the efforts of medical providers working on the frontlines of the COVID-19 pandemic and recognizes the personal and professional risks they face in answering this call to duty. Accordingly, CMIC RRG is supporting efforts around the country to promote civil liability immunity laws similar to executive order issued by New York’s Governor Cuomo on March 23, 2020 (see below).
EXCERPT from NY Executive Order 202.10 Subdivision (2) of section 6527, Section 6545, and Subdivision (1) of Section 6909 of the Education Law, to the extent necessary to provide that all physicians, physician assistants, specialist assistants, nurse practitioners, licensed registered professional nurses and licensed practical nurses shall be immune from civil liability for any injury or death alleged to have been sustained directly as a result of an act or omission by such medical professional in the course of providing medical services in support of the State’s response to the COVID-19 outbreak, unless it is established that such injury or death was caused by the gross negligence of such medical professional;
Any other questions, please feel free to contact CMIC RRG at any time at 866.849.2774.