On June 21, 2021, OSHA released for publication staggering requirements related to healthcare practice protocols.  Unless you qualify under an exemption, the new rules will require many practice protocols including:

  • Mandatory extensive COVID-19 workplan for each practice location
  • Mandatory workplace COVID-19 risk assessment
  • Mandatory policies and procedures compliant with CDC’s “Guidelines for Isolation Precautions”
  • Mandatory masks and social distancing
  • Mandatory physical barriers
  • Mandatory ventilation requirements
  • Mandatory employee screening
  • Mandatory – new regulations regarding employee confirmed or suspect COVID exposure, COVID testing for employees at office expense, payment of regular wages for employees removed from practice due to COVID disease or exposure
  • Mandatory employee training

While these requirements could be devastating to a small healthcare practice, there are potential exemptions.  Your practice may be exempt if you:

  • Implement and maintain a policy to screen every non-employee who enters your facility and not allowing individuals with COVID or COVID symptoms from entering your facility. In the rules, screening is defined as simply asking non-employee individuals who enter the facility the standard list of questions regarding symptoms and possible exposure to COVID-19, or
  • Ensure the facility is in a well-defined area where there is no reasonable expectation that any person with suspected or confirmed COVID-19 would be present (seems impossible to ensure)


Understand these are different from prior CDC recommendations.  OSHA requirements are Federal LAW – they are not optional unless you want to be subject to the oversight authority of OSHA.

Simply put, unless you are willing to continue screening non-employees who enter your practice, your business operations just got very complex and very costly.  There are currently no expectations on when these guidelines will end.

See: https://www.osha.gov/sites/default/files/covid-19-healthcare-ets-reg-text.pdf