As if we didn’t have enough to worry about!
Yesterday I answered a call from a mildly panicked podiatrist after learning about a physician group (non-podiatry) in her building who received a disturbing email from MIOSHA (Michigan OSHA) a few days before Christmas.
In a nutshell, this is what it said:
“The Michigan Occupational Safety and Health Administration (MIOSHA), General Industry Safety and Health Division or Construction Safety and Health Division, has received a complaint alleging safety and/or health hazards at your worksite located at:
The hazards related to coronavirus. A list of the alleged hazard(s) is as follows:
- Employer is not complying COVID-19 regulations seriously.
- Doctors in the facility take off their masks when talking to staff.
- Employer is not enforcing social distancing in the office.
- Employer has instructed staff not to inform patients about COVID-19 positive cases.
- Employer is circumventing the 10-day quarantine to get back to work which violates CDC rules.
- Non-medical personnel have been denied the opportunity to work remotely.
Based on this complaint, we are conducting an off-site complaint investigation. We do not intend to initiate an on-site inspection currently. As part of the off-site complaint investigation, you are requested to perform a self-audit of the alleged hazardous conditions and take appropriate steps to protect employee health, including complying with the MIOSHA Emergency Rules for Coronavirus Disease 2019 (COVID-19). We ask that you complete these steps within two workdays of the date of this letter. . .
In your response to this letter, we will need to see in particular:
- Copies of company’s policy and implementation of COVID-19 based on CDC’s and MIOSHA’s guidelines.
- Copies of procedures and records for screening employees before entry into the facility.
- Copies of policy for testing and quarantining employee who tested positive for COVID-19.
- Copies of policy for implementing contact tracing of employees who may be exposed to COVID-19 individuals.
- Copies of policy addressing social distancing; including photos of markings on the floor or chairs showing social distancing.
- Copies of policy for cleaning and disinfecting surfaces in the facility, and photos of chemicals used for disinfection.
- Photos of masks and other types of personal protective equipment being provided for employees’ use in the facility.
- Copies of policy for enforcement of wearing masks, and other types of personal protective equipment in the facility
If you provide the requested information, we will probably not need to conduct an on-site investigation. Your responses may be shared and discussed with employees for verification. If we do not receive a response from you within two workdays indicating that appropriate action has been taken or that no uncontrolled hazard exists and why an on-site inspection may be conducted. . .”
Obviously, this complaint was filed by an employee who may or may not have been correct in his/her allegations, but I wanted to share this information so that you are prepared in the event that you find yourself in a similar situation.
In response, I have taken the liberty of compiling additional COVID-related policies, forms, and examples based on the requested documents listed above. These are available to active Pinnacle practices and Practice Engagement Program (PEP) subscribers in the member library (under the “COVID-19 Related Resources”). Keep in mind that COVID compliance regulations vary from state to state but in any case, this is not something to be taken lightly.
Documents included and recently added in the COVID-19 Related Resource Tab include:
• COVID addendum for Employee Handbook
• COVID Cancelation Policy
• Early Arrival During COVID
• Suggested Office Precautions
• Basic OSHA requirements (not state specific)
• COVID-19 information for patients
• Telehealth information (coding and documentation and updates)
• COVID Training Verification Form
• Exposure Risk Assessment Form
• Patient Questionnaire for check-in (attached here as an example of library content)
• Infection Control Plan (sample to be filled in as well as example of completed document)
• Example of state specific Temporary COVID Standards for the Workplace
• Employers Guide to COVID
• Employee Daily Screening Form
• Notification Policy for when Exposure Occurs
• 7 Posters for display in office (patient and staff education)