By Patrick O'Brien, JD, legal coordinator, American Med Spa Association

Since part one of this article was originally posted, the outbreak of Coronavirus, which causes the disease COVID-19, has spread rapidly in the U.S., with cases in every state and hundreds of cases in our largest cities. The World Health Organization has labeled the outbreak a "global pandemic," and nations, states and cities have declared emergencies. Many public events have been cancelled or postponed, and the Center for Disease Control (CDC) and other authorities are requesting that people take certain steps to help limit the spread of infection. Many businesses are requesting that their employees work from home; unfortunately, medical spas are not in a position to do this.

In part one of this article, we discussed an employer's duties in events like this, as well as the need to develop policies and response plans. Recently, the U.S. Occupational Safety and Health Administration (OSHA) published a guidebook about preparing workplaces for COVID-19 for employers. We recommend that you read it in full. In addition to that information, here are some ideas for the challenges unique to medical spas:

• Increase the use of personal protective equipment (PPE): Because of the close, personal nature of medical spa services, the chances of transmission are elevated. You may want to consider increasing the levels of PPE for all patient encounters. If you currently only use gloves for consults, consider adding a mask and eye shield, as well as more thoroughly ventilating the rooms.
• Sterilize or remove commonly touched items: your waiting room sees the most traffic of any part of your facility, but it probably receives the least frequent cleanings. Make it a point to sterilize doors, chairs and counters multiple times each day or after each use. If you have a pen cup, remove it and use one pen that is wiped between uses. If you use a tablet-based system, sterilize it between uses or have your front-desk person take verbal instructions.
• Limit chances for contact: Your prescribing providers—physicians, physician assistants and nurse practitioners—are critical members of your team, and, to the extent state laws allow, may want to perform patient examinations via telemedicine, provided proper supervision of the facility is maintained. Before patients come in for appointments, they should be prescreened and asked to reschedule if they have any symptoms or prior exposure. Employees who can work remotely should be permitted to do so.
• Broaden your providers' scopes: Identify your core services and make sure that as many of your employees who are able to provide the services are trained to do so (staying within each person's licensed scope of practice). By having a cross-trained team, you can minimize disruptions if a single member is forced to miss work for any reason.

It also is extremely important that you communicate these efforts to your patients. Not only will it build confidence in your services, it will also help patients assist in the efforts. You may want to include a sign on the door or at the front desk to this effect:

We take the threat of the Coronavirus/COVID-19 very seriously. To combat the spread of this disease and to protect our patients and employees, we have instituted protocols and strengthened our already thorough sterilization procedures.

If you have questions about these procedures, please ask.

To assist us today, please cover coughs and sneezes, and refrain from touching surfaces. We have provided tissues and hand sanitizer for your use. Thank you.

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