PA DOH Issues Revised Guidance on Elective Procedures in Ambulatory Surgery Facilities

April 27, 2020Alerts

The Pennsylvania Department of Health (DOH) has issued revised guidance effective April 27, 2020, permitting ambulatory surgery facilities (ASFs) to resume the performance of elective procedures, as long as the ASF makes an affirmative decision that it is able to do so without jeopardizing the safety of patients and staff or the ASF’s ability to respond to the COVID-19 emergency.

In determining whether to resume elective procedures, an ASF must review the Joint Statement issued by the American College of Surgeons, American Society of Anesthesiologists, Association of Perioperative Registered Nurses, and American Hospital Association, and consider the operational guidance described therein to the extent applicable to the ASF.  To the extent that the ASF performs procedures on minors, it must also consider the Guidance of the Children’s Hospital Association.

Importantly, an ASF does not need approval from the DOH to resume elective procedures.  However, although not stated in the revised Guidance, failure to adhere to the Joint Statement and Guidance of the Children’s Hospital Association to the extent applicable to the ASF could potentially be a basis for survey deficiencies at a later date (as well as raising professional liability concerns).

The revised Guidance has other critical information for ASFs, and should be read carefully.  Notably:

  • ASFs must notify the DOH when resuming procedures by reporting on the PSRS (the PA Patient Safety Reporting System).
  • ASFs are not required to report the presence of a patient or staff member with COVID-19 in the facility through PSRS as an infrastructure failure.
  • Visitor access should be limited, and ASFs may adopt a new visitor policy without DOH approval.
  • ASFs must continue to submit daily survey reports to the DOH in accordance with this amended order.

Also, the Joint Statement advises that ASFs should not re-open for elective procedures until there has been a sustained reduction in the rate of new COVID-19 cases in the relevant geographic area for at least 14 days.  This directly impacts when ASFs can reasonably resume elective procedures under this Guidance.

For more information on how the revised Guidance impacts your practice or ASF, please do not hesitate to contact us.