CMS Lays Out Roadmap for Restarting In-Person Care Besides COVID-19 Treatment


As the White House looks to soon reopen parts of the United States, the Centers for Medicare & Medicaid Services (CMS) has released its first set of guidelines for healthcare providers in regions that have seen stabilizing COVID-19 trends. The guidelines relax prior CMS recommendations that facilities limit and postpone non-essential care and elective procedures.

CMS’s new recommendations, announced on April 19, specifically target regions that have reached Phase I of the Trump Administration’s Guidelines for Opening Up America Again. Phase I regions will have met certain “Gating Criteria,” including showing that within a 14-day period, there has been a downward trajectory in documented cases or positive tests, as well as a downward trajectory of influenza-like and COVID-19 cases. Regions must also show that they have adequate hospital capacity and a robust testing plan for at-risk healthcare workers.

While these regions would have relatively lower incidences of COVID-19, CMS still strongly encourages the maximum use of the expanded telehealth options. But where in-person care is needed, “Non-COVID-19 care should be offered to patients as clinically appropriate and within a state, locality, or facility that has the resources to provide such care and the ability to quickly respond to a surge in COVID-19 cases, if necessary.” CMS Administrator Seema Verma described the guidelines as providing “a gradual process for restarting non-COVID-19 essential care while keeping patients safe.”

The guidelines list a number of general and specific considerations, including:

As the guidelines emphasize, careful planning will be required to resume in-person, non-COVID-19 care. Given the dynamic environment of the pandemic, healthcare providers must be prepared to closely coordinate with state and local authorities. CMS expects to issue additional recommendations in the future.


© Copyright 2025 Squire Patton Boggs (US) LLP
National Law Review, Volume X, Number 112