The COVID-19 public health emergency continues to pose new and unprecedented challenges for our health-care system and individual physicians and practices. APMA is here to help its members navigate these difficult times and continue to deliver the highest-quality foot and ankle care to patients. This section provides a wealth of resources for everything from clinical concerns to practice management and financial guidance.
UPDATE: CMS Announces Roadmap to the End of the Public Health Emergency
APMA has compiled answers to members' frequently asked questions.
Considering the current environment surrounding the COVID-19 pandemic, be sure you take stock of your personal health and well-being. APMA has many resources available to help you.Be Well
Page Updated March 12, 2022
In response to the COVID-19 pandemic, the CARES ACT expanded loan options for small businesses, and we expect podiatric offices to take advantage of one or both loan options. Detailed information about both options is available on this page.
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Paycheck Protection Program
Economic Injury Disasters Loan and Loan Advance
Marcum, LLP Articles for Podiatric Practices
Additional Assistance and Resources
Webinar: How Your Practice Can Survive COVID-19
Podcast: Applying for SBA Loans
As part of the CARES Act and the second December 2020 $900 billion COVID relief package, Congress provided the initial round and second round of PPP loans that were available to small businesses impacted by the COVID-19 crisis. Eligible entities for both rounds included:
First Draw PPP Loans (FDLs)
|The eligible entity must be 500 employees or fewer.|
Second Draw PPP Loans (SDLs)
The eligible entity must be 300 employees or fewer and have already received a first draw PPP loan.
The eligible entity must also demonstrate at least a 25 percent reduction in the first, second, or third quarter relative to the same 2019 quarter. If a business was not in operation in 2019, the Act provided applicable timelines for demonstrating a loss.
An eligible entity may only receive one PPP second draw loan. For loans of $150,000 or less, the entity could have submitted a certification attesting that the entity meets the revenue loss requirements on or before the date the entity submits its loan forgiveness application.
FDL and SDL PPP borrowers may receive a loan amount of up to 2.5 times their average monthly payroll costs (capped at $100,000 per employee annualized), in 2019, 2020, or the year prior to the loan. The maximum loan amount is $10 million for first-time borrowers and $2 million for second-time PPP borrowers. Both first and second draw loans are forgivable if the funds are used on the following eligible costs:
To be eligible for full loan forgiveness, PPP borrowers must spend no less than 60 percent of the funds on payroll over a covered period of their choice between eight and 24 weeks.
In the December 2020 COVID-19 relief package, Congress also addressed the following:
FDL and SDL forgiveness:
Recipients of both first draw and second draw loans would be eligible for forgiveness equal to the sum of their payroll costs, as well as covered mortgage, rent, and utility payments, covered operations expenditures, covered property damage costs, covered supplier costs, and covered worker protection expenditures incurred during the covered period. The 60/40 cost allocation between payroll and non-payroll costs in order to receive full forgiveness will continue to apply.
Borrowers should contact their lenders for additional information on the loan forgiveness process.
There are two loan forgiveness applications, dependent on how much money your practice received:
APMA encourages borrowers to contact their accountants to assist with preparing the appropriate documentation. There is no explicit deadline for submission, PPP loan recipients should contact their lender directly for information on submitting the loan forgiveness application.
NOTE: Borrowers had until December 31, 2020, to restore their full-time employment and salary levels for any changes made between February 15 and April 26, 2020.
The PPP Flexibility Act added additional exemptions to the reduction in the amount of loan forgiveness. Under the new law, the amount of loan forgiveness will not be reduced based on a reduction in the number of full-time equivalent employees if the borrower, in good faith:
Borrowers may owe money when their loan is due if they use the loan amount for anything other than payroll costs, mortgage interest, rent, and utilities payments after receiving the loan. Borrowers will also owe money if they did not maintain their staff and payroll. If any or portion of the loan is not forgiven, these loan terms apply for all borrowers.
Changes in Ownership if Owner has received a PPP Loan
On October 2, 2020, the SBA also released additional guidance on whether or not the SBA needs to approve any change in ownership. The SBA clarified that for 7(a) loans made under the PPP, no approval is required if the borrower has repaid its PPP loan in full or if it has applied for forgiveness with a final determination on forgiveness having been made (as evidenced by the SBA's payment to the lender) with either the full amount of the loan forgiven or the borrower having repaid any unforgiven amount.
If you have PPP amounts outstanding, it depends on several factors.
The borrower must seek approval of the SBA before effectuating any other ownership change, regardless of whether it is an equity or asset sale. As part of the approval process, the borrower must submit certain information to the SBA (through its lender), including the following:
The SBA will issue a determination within 60 days of the receipt of a complete request.
Additional Resources from APMA Partners
Paycheck Protection Program (PPP) FAQ
Still Available - Loan Increase Available to Existing EIDL Recipients
While the SBA is not accepting new EIDL applications, if you previously received an EIDL, you can apply for an increase up to the amount you qualify for or the $2,000,000 cap, whichever is lower. The SBA began approving loans greater than $500,000 on Oct. 8, 2021. In order to apply for an increase, you must login to your account in the COVID EIDL portal.
The deferment period for any loan increase will be 24 months from the date the COVID EIDL loan was first disbursed (not the date of increase). If you received a loan in 2020 or 2021 that does not have a 24-month deferment period, SBA will reset your deferment period to 24 months from the date your loan was first disbursed to you.
The amount of loan increase that you are eligible for is determined by the loan amount that you would be eligible for if you applied today minus the loan (including any increases) that you have already received. You may apply for an additional increase even if you have already applied for and received previous loan increase. For example, if you are eligible for a $700,000 COVID EIDL loan today, but your current COVID EIDL loan is $500,000 (either because your maximum loan amount was capped in the past or because you elected to take less than the full amount), you are eligible to request an increase of $200,000.
EIDLs are available to small businesses, independent contractors, and sole proprietors in declared disaster areas, which now includes all 50 states and territories. To qualify for an EIDL, the applicant must have suffered “substantial economic injury” from COVID-19. Substantial economic injury generally means a decrease in income from operations or working capital with the result that the business is unable to meet its obligations and pay ordinary and necessary operating expenses in the normal course of business.
Eligible recipients can receive up to $2 million in assistance, which can include a $10,000 Emergency EIDL (cash advance grant). EIDL loans under the CARES Act are based on a company’s actual economic injury determined by the SBA (less any recoveries such as insurance proceeds)
Unlike PPP, EIDLs generally do not have any loan forgiveness provisions. However, applicants that already applied for an EIDL loan can refinance their EIDL under the PPP. Additionally, the Emergency EIDL loan (next section) of up to $10,000 is not expected to be repaid, even if you are subsequently rejected for an EIDL.
$10,000 Emergency EIDL (Cash Advance Grant)
Proceeds of the overall EIDL may be used for:
Applications for an EIDL and Emergency EIDL can be submitted from January 31–December 31, 2020.
Eligible small businesses can apply for a loan at https://disasterloan.sba.gov/ela. For questions, please contact the SBA disaster assistance customer service center at 1-800-659-2955 (TTY: 1-800-877-8339) or email firstname.lastname@example.org. Eligible businesses should expect a disbursement of monies within five business days of a successful application.
The interest rate on EIDL loans is 3.75 percent fixed for small businesses and 2.75 percent for nonprofits. The EIDL loans have up to a 30-year term and amortization (determined on a case-by-case basis).
Economic Injury Disaster Loan (EIDL) and Emergency EIDL (Cash Advance) FAQ
The accounting and business advisory firm of Marcum, LLP is providing information to help podiatric practices survive during the pandemic and economic downturn and to start planning for the recovery.
Article 1: Guide to COVID-19 Small Business Loans
Article 2: Accessing Various Forms of Capital for Your Practice
Article 3: Building a Path Forward for Your Podiatry Practice
Article 4: Tools to Help Your Podiatry Practice Survive and Thrive
APMA has compiled resources on other SBA loans, state loans for small businesses, private resources and consumer assistance available to podiatric practices.
APMA partnered with Marcum LLP to offer its members a one-hour webinar about recent COVID-19 legislation and resources for you and your practice. Download a copy of the presentation and a copy of the Q&A from the presentation. Marcum LLP provides a detailed guide to small business loans as an update to its How Your Practice Can Survive COVID-19 webinar.
Disclaimer: This resource is for information purposes only. APMA advises doctors of podiatric medicine to speak with an attorney or financial advisor duly licensed in their jurisdiction.
Update: CMS Announces Roadmap to the End of the Public Health Emergency
Through the end of 2024, there are four main non-face-to-face service types podiatrists can provide. A podiatrist’s ability to employ these services and be reimbursed for these services may differ based on the patient’s insurance and state licensure. Always check with payer and state licensure guidelines before providing any service.
The four main non-face-to-face service options include:
1. Telehealth services that are normally furnished in person which are instead furnished remotely using interactive, real-time telecommunication technology
Through the end of 2024, CMS and some other payers are allowing certain services to be provided via telehealth with the provider in any location and the patient in any location.
4. Online digital E/M services
APMA suggests obtaining informed consent for these services. APMA further suggests that members advise patients that there will be a charge for these services, that copays and deductibles may apply, and referrals may be necessary if required by the insurance plan.
HHS Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency - https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html
Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency http://hhs.com/assets/docs/covid-final-ifc.pdf
CMS Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
Current Procedural Terminology (CPT®) is copyright 1966, 1970, 1973, 1977, 1981, 1983–2020 by the American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association (AMA). Reference: 2020 CPT Professional
CPT codes and their descriptions do not reflect or guarantee coverage or payment. The existence of a CPT / HCPCS code does not guarantee payment for the service it describes. Coverage and payment policies of governmental and private payers vary from time to time and for different areas of the country. Questions regarding coverage and payment by a payer should be directed to that payer. APMA and its employees, consultants, and officers do not claim responsibility for any consequences or liability attributable to the use of any information, guidance, or advice contained in this communication or liability attributable to the use of any information, guidance, or advice contained in this communication.
The Consolidated Appropriations Act of 2021 includes COVID relief legislation. Read a high-level summary of provisions that may be of interest to APMA members. APMA will continue to review the legislation and provide more information to members as it becomes available.
Congress and the administration have heard from medical practices nationwide about the substantial impact of COVID-19 on their businesses. APMA’s partner, Capitol Hill Consulting Group, has created the following summary of provisions in the Coronavirus Aid, Relief, and Economic Security (CARES) Act that may have an impact for our member physicians. For more information, email email@example.com.
Be sure to check out APMA's eAdvocacy website to learn about legislation impacting the profession and the patients we serve, and to voice your opinion on these bills to your elected federal legislators.
APMA has been working to protect you and your practice since the COVID-19 public health practice began. Be sure to check out APMA's eAdvocacy website to learn about legislation impacting the profession and the patients we serve, and to voice your opinion on these bills to your elected federal legislators.
Members can find all COVID-19 CMS-related news on this page. For relevant COVID-19 related APMA resources, including APMA recommendations and access to financial resources during this public health emergency, visit www.apma.org/COVID19.
|Physicians and Non-Physician Practitioners||
|All Other Providers and Suppliers (including DMEPOS)||
Additionally, the FAQ addresses the process for physician and non-physician practitioners to initiate temporary Medicare billing privileges, including through an enrollment hotline, licensure, revalidation, and more.
|District of Columbia||Massachusetts||North Dakota||Washington|
Page last updated May 16, 2022.
Request to Report Late Due to Extenuating Circumstances - PRF Reporting Period 2 Recipients—submit your report if you are required to report no later than May 18, 2022!
Looking for information on past rounds of Provider Relief Funds?
APMA is very pleased to announce that the HRSA has re-opened the Provider Relief Fund Reporting Portal for PRF recipients who were unable to report during Reporting Period 2 because of extenuating circumstances. HRSA took this action after hearing from APMA and other member associations, whose members expressed their serious concerns about the Period 1 funding they received being recouped despite good faith intents to report and the impact it would have on their practices. In order to report, providers will need to submit a Request to Report Late Due to Extenuating Circumstances before midnight on Wednesday, May 18. HRSA lists the following extenuating circumstances that would allow a PRF recipient to belatedly report for PRF monies:
Providers can find the process for submitting a Late Report Request via HRSA’s website. If you have not already registered for the PRF Reporting Portal, you will need to do so prior to submitting your request. Registration instructions are on the PRF Reporting webpage. In your late report request, you must indicate and attest to a clear and concise explanation related to the applicable extenuating circumstance; however, supporting documentation will not be required, and HRSA will notify you directly if your request is approved or denied. If your request is approved, you will received a notification to complete the report, which must be done within 10 days of receiving the notification. Providers whose Request to Report Late Due to Extenuating Circumstances is denied will remain non-compliant with the Terms and Conditions and will be required to return all funds to HRSA that were not reported on in the applicable reporting period. Review the Returning Funds webpage for additional details.
Providers may not utilize the Request to Report Late Due to Extenuating Circumstances process to request an opportunity to make edits or adjustments to an already submitted report. Contact the Provider Support Line at 866-569-3522 for assistance regarding revising a submitted report.
|Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)
|Deadline to Use Funds||Reporting Time Period||Request to Late Report Due to Extenuating Circumstances|
|Period 1||From April 10, 2020 to June 30, 2020||June 30, 2021||July 1 to September 30, 2021*||Now closed|
|Period 2||From July 1, 2020 to December 31, 2020||December 31, 2021||January 1 to March 31, 2022||Yes - May 2 - May 18, 2022
If request is approved, you have 10 days from the notification to complete your report.
|Period 3||From January 1, 2021 to June 30, 2021||June 30, 2022||July 1 to September 30, 2022||n/a|
|Period 4||From July 1, 2021 to December 31, 2021||December 31, 2022||January 1 to March 31, 2023||n/a|
|Period 5||From January 1, 2022 to June 30, 2022||June 30, 2023||July 1, 2023 to September 30, 2023||n/a|
* Please note, HHS has extended this deadline to November 30 as a grace period, and providers who do not report by September 30 will still be considered out of compliance. However, no collection activities or similar enforcement actions will be initiated during this 60-day grace period.
Reporting Period 1 and 2 Resources
APMA has worked with Hart Health Strategies to create a webinar during the first Reporting Period 1 for members to assist in navigating reporting, as well as a detailed summary.
Podiatrists who have gone through the reporting process recommend accessing the following documents and information prior to reporting:
Members can review CMS’ Post-Payment Notice of Reporting Requirements for additional information on Reporting Period 2. Additional CMS Resources include:
On September 29, the Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), will start accepting applications for Phase 4 of the Provider Relief Fund (PRF).
Included in this round was $25.5 billion in new funding for providers affected by the COVID-19 pandemic, specifically those who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, in addition to providers who are able to document revenue loss and increased operating expenses associated with the pandemic. Lost revenue and expenses will be calculated from the period of July 1, 2020, to March 31, 2021. To see if you qualify for areas deemed “rural,” view the Rural Health Grants Eligibility Analyzer on the HHS website.
On December 14, HHS announced the distribution of approximately $9 billion PRF Phase 4 payments to health-care providers who have experienced revenue losses and expenses related to the COVID-19 pandemic. The average payment announced for small providers was $58,000, for medium providers was $289,000, and for large providers was $1.7 million. More than 69,000 providers in all 50 states, Washington, DC, and eight territories will receive Phase 4 payments. Payments for this distribution will start by December 17, 2021.
HHS released the Phase 4 payment methodology in September, making it available to providers during the application period. Approximately 75 percent of Phase 4 funding is being distributed based on expenses and decreased revenues from July 1, 2020, to March 31, 2021. HHS is reimbursing a higher percentage of losses and expenses for smaller providers—which generally entered into the COVID-19 pandemic on worse financial footing, have historically operated on slimmer financial margins, and typically care for vulnerable populations—as compared to larger providers.
HHS is distributing the remaining 25 percent of Phase 4 funding as “bonus” payments based on the amount and type of services provided to Medicare, Medicaid, or CHIP patients. Similar to the American Rescue Plan (ARP) Rural payments announced last month, HHS is using Medicare reimbursement rates in calculating these payments to mitigate disparities due to varying Medicaid reimbursement rates.
Additionally, HHS has updated the Terms and Conditions for Phase 4 and ARP Rural payments to ensure relief funds are being used to address the financial impact of COVID-19. Recipients whose payment(s) exceed $10,000 are required to notify HHS of a merger with or acquisition of any other health-care provider. Providers who report a merger or acquisition may be more likely to be audited to ensure compliant use of funds.
HHS is currently reviewing the remaining Phase 4 applications and will make the remainder of Phase 4 payments in 2022.
Recipients of Provider Relief Fund payments must agree to the Terms and Conditions specific to the distribution in which they received a payment or reimbursement.
Providers must attest to program Terms and Conditions in order to receive payment, such as:
In reviewing the terms and conditions, there are a few key items for providers to consider, as detailed below.
Possible or actual cases. Providers must attest that they “[provide] or provided after January 31, 2020, diagnoses, testing, or care for individuals with possible or actual cases of COVID-19.” The initial terms and conditions did not include the specific date. While this information is not included in the terms and conditions, HHS on its website further noted that “HHS broadly views every patient as a possible case of COVID-19.” With the addition of the date and the HHS clarification, providers may be able to attest to this requirement if they treated any patient after January 31, whether via telehealth or in person.
Reallocating funds. At this time, there is a not a process to allow an entity to reallocate the funds to different a TIN in light of changes in ownership or new providers. This situation is a particular issue given that the legacy TINs may not be able to attest to the ability to treat patients and, as such, may have difficulty in attesting to retain the funds.
Bans balanced billing. In essence, to retain the funds, a provider must not balance bill for “all care for a presumptive or actual case of COVID-19.” For those patients, the provider must not seek from the patient more than the patient would have been obligated to pay if the provider was an in-network provider. While it is still unclear which cases would be “presumptive or actual” cases, one could attest that this subset of patients is different from “possible or actual” (which is essentially all patients) but would still apply to all patients in that subset, regardless of payer. And, given that this language does not have a similar date qualifier (i.e., the January 31 date), it is unclear when HHS expects the balance billing requirement to be in effect. This situation is particularly troubling, given that, so far, there has been no discussion regarding the amount of payment required.
Note that the secretary has concluded that the COVID-19 public health emergency has caused many health-care providers to have capacity constraints. As a result, patients who would ordinarily be able to choose to receive all care from in-network health-care providers may no longer be able to receive such care in-network. Accordingly, for all care for a presumptive or actual case of COVID-19, the recipient certifies that it will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network recipient.
No other reimbursement. One additional requirement is that the “recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.” Unfortunately, HHS did not provide enough information for providers to easily untangle how to provide appropriate accounting for these items, especially given that many health-care services may be under additional obligations (e.g., Medicare payment for certain telehealth services), interactions with other government programs (e.g., the Paycheck Protection Program), etc.
Salary cap. The funds provided cannot be used to “pay the salary of an individual, through a grant or other extramural mechanism, at a rate in excess of Executive Level II.” According to OPM, Executive Level II is $197,300 for 2020. On its website, HHS has stated that “these are payments, not loans” but has not clarified whether this is an “extramural mechanism” subject to this restriction.
Use of funds. Another key requirement is that the “recipient certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and shall reimburse the recipient only for health-care related expenses or lost revenues that are attributable to coronavirus.” This requirement is confusing at best, and it seems virtually impossible to use the fund at the same time for both care and lost revenue. Therefore, additional clarity is needed, especially in light of the extensive reporting requirements for the program.
Not an exhaustive list. The terms and conditions include a statement that “[t]his is not an exhaustive list and you must comply with any other relevant statutes and regulations, as applicable.” Further, the notice states that “[n]on-compliance with any term or condition is grounds for the secretary to recoup some or all of the payment made from the Relief Fund.”
Subcontractors. Another key statement is that “[t]hese terms and conditions apply directly to the recipient of payment from the Relief Fund. In general, the requirements that apply to the recipient, also apply to subrecipients and contractors, unless an exception is specified.”
Additional language from $20 billion allocation. The additional language in the terms and conditions for the second tranche (e.g., $20 billion allocation) is as follows: “The recipient shall also submit general revenue data for calendar year 2018 to the secretary when applying to receive a payment, or within 30 days of having received a payment. The recipient consents to the Department of Health and Human Services publicly disclosing the payment that recipient may receive from the Relief Fund. The recipient acknowledges that such disclosure may allow some third parties to estimate the recipient’s gross receipts or sales, program service revenue, or other equivalent information.”
APMA is providing resources to assist members with running their offices in a safe manner for their patients and staff during the public health emergency.
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Risk Management Resources and Checklists
Elective Procedures and Non-Emergent Non-COVID-19 Health Care
While these resources provide background information and practice solutions for podiatric physicians, APMA is not rendering legal or other professional advice. APMA encourages readers of these resources who need assistance to consult with an attorney duly licensed in your jurisdiction.
The CDC and CMS have information, recommendations, and guidance for nursing homes and long-term care facilities. If you provide care at nursing homes or long-term care facilities, check out these resources.
The CDC provides general information on Nursing Homes and Long-Term Care Facilities as it relates to COVID-19.
CMS has created the Nursing Home Resource Center where you can find nursing home resources including COVID-19 public health emergency response information and a series of short podcasts for front-line nursing home staff.
The CDC provides Interim Infection Prevention and Control Recommendations to Prevent SARS-CoV-2 Spread in Nursing Homes including guidance related to how to handle a New Infection in Healthcare Personnel (HCP) or Resident.
CMS provides recommendations relating to Nursing Home Visitation – COVID-19, including visiting providers. Be sure to check with individual facilities you visit for any updated guidance.
The CDC’s Interim Infection Prevention and Control Recommendations to Prevent SARS-CoV-2 Spread in Nursing Homes includes information on testing healthcare personnel and evaluating and managing health-care personnel.
Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic describes recommendations regarding: 1) source control and physical distancing for fully vaccinated HCP; 2) universal use of PPE for HCP; and 3) testing.
CMS provides recommendations for state and local officials regarding nursing home reopening including access to adequate testing. CMS also has guidance for facilities to meet requirements related to testing residents and staff, including individuals providing services under arrangement and volunteers.
The CDC has Information About COVID-19 Vaccines for Long-term Care Facility Residents and Family Members available so you can help protect yourself and the people around you.
On May 11, 2021, CMS posted an Interim Final Rule - COVID-19 Long-Term Care Facility Vaccine Immunization Requirements for Residents and Staff.
APMA, the CDC, and CMS provide information, recommendations, and guidance regarding the COVID-19 vaccination.
CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule with Comment Period
This interim final rule with comment period revises the requirements that most Medicare- and Medicaid-certified providers and suppliers must meet to participate in the Medicare and Medicaid programs. CMS states that changes are necessary to help protect the health and safety of residents, clients, patients, PACE participants, and staff, and reflect lessons learned to date as a result of the COVID-19 public health emergency. The revisions to the requirements establish COVID-19 vaccination requirements for staff at the included Medicare- and Medicaid- certified providers and suppliers.
Members have asked APMA about mask requirements and face coverings in podiatric offices in light of recent (May 16, 2021; updated September 16, 2021) CDC guidance for those fully vaccinated. APMA recommends that podiatric offices comply with state or local jurisdiction rules regarding face-covering requirements as they apply to businesses and health-care settings.
You should encourage your unvaccinated patients to follow recommendations on How to Protect Yourself and Others. APMA also recommends that podiatric physicians encourage eligible patients to get vaccinated and receive booster shots, as appropriate.
Additional Guidance for Daily Activities; Guidance for Activities, Gatherings, and Holidays; and, Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic are available from the CDC.
APMA is not providing legal advice and encourages members to speak with a duly licensed attorney in their jurisdiction.
To support members and podiatric offices, APMA has engaged state and federal policymakers on the administration of vaccinations and following are recent examples of successful efforts:
APMA’s House of Delegates has adopted the following policy propositions regarding vaccinations:
Policy Proposition 2-21: Podiatric Physician Routine Immunization
APMA encourages doctors of podiatric medicine to be routinely immunized, especially when safe and effective vaccines are available, and especially for diseases that have potential to become epidemic or pandemic (e.g., influenza or SARS-CoV-2). Vaccines are essential for protecting individuals and communities from vaccine-preventable diseases and outbreaks. Vaccine-preventable diseases can be a threat to our health and vaccines can provide population-wide protection against disease. Notwithstanding, APMA recognizes and respects that some doctors of podiatric medicine may be unable to take certain vaccinations for medical reasons or because of firmly held religious beliefs, and APMA encourages such individuals to take appropriate precautions in effort to avoid spreading communicable diseases.
Policy Proposition 3-21: Podiatric Physicians Administering Vaccines
APMA supports including podiatric physicians, and podiatric residents, and podiatric medical students in the pool of professionals who can administer vaccines, especially when called upon in times of need for a disease that has potential to become epidemic or pandemic (i.e., influenza or SARS-CoV-2). Podiatric physicians and surgeons undergo education and training like their allopathic and osteopathic physician colleagues and possess more than enough experience to administer vaccines. Doctors of podiatric medicine are licensed, independent practitioners, and as such, APMA urges federal, state, and local governments to authorize podiatric physicians and podiatric residents to administer vaccines without any supervision requirements.
APMA's regulatory consultant, Hart Health Strategies Inc., has prepared a COVID resource document on the topic of COVID vaccines.
The CDC provides a printable COVID-19 resource you can display in your office or provide to your patients.
Information on the different COVID-19 vaccines, including information on vaccines in clinical trials, is available from the CDC.
The CDC provides information on Who Is Eligible for a COVID-19 Vaccine Booster Shot and the We Can Do This campaign has infographics and social media content you can share.
The New England Journal of Medicine (NEJM) has a COVID-19 Vaccine Resource Center, which features a collection of resources on COVID-19 vaccines, including frequently asked questions, continuing medical education, published research, and commentary.
CMS provides information related to COVID-19 vaccine administration to ensure the vaccine is covered and available free of charge for every American. CMS also has a tool kit regarding vaccine administration specifically for health-care providers.
Clinical resources from the CDC are available for administration, storage and handling, patient education, and more for COVID-19 vaccine.
The CDC has information for preparing your practice for COVID-19 vaccination.
CMS has published information about the COVID-19 vaccine payment rate, vaccine coding guidance, and how to bill for COVID-19 shot administration.
If you participate in the CDC COVID-19 Vaccination Program, you must:
You also can't:
Q: Can podiatrists prescribe and/or administer vaccines for COVID-19?
On March 11, HHS made an amendment to the Public Readiness and Emergency Preparedness (PREP) Act Declaration to allow more qualified professionals to prescribe, dispense, and administer COVID-19 vaccinations, including podiatrists, recently retired podiatrists, and podiatric medical students. HHS has determined that the PREP Act clearly preempts state law. Therefore, regardless of scope of practice restrictions, DPMs, retired DPMs, and students may serve as vaccinators so long as they meet certain conditions. Ultimately, states and territories may choose which qualified persons to use for vaccinations in their jurisdiction. Read more: Biden Administration Authorizes DPMs, Students to Administer COVID-19 Vaccine.
Several states have already authorized podiatrists to administer vaccines, and as of April 1, 2021, APMA is aware of nine states that have taken action:
State requirements that do not effectively prohibit qualified persons, such as additional training, are not preempted by the PREP Act. You will need to contact the state department of health for more information or to ask questions.
APMA encourages members to contact their state health department or licensing board for more information.
The CDC has materials for preparing your practice for COVID-19 vaccination, including the CDC's Vaccine Training Modules and a printable "Facts about COVID-19 Vaccines" resource you can provide to your patients.
Q: Can podiatrists require their office staff to receive the COVID-19 vaccination?
Generally, you can require your employees to get vaccinated if by not getting the vaccine they pose a direct threat to customers or other employees. In the context of a physician's office, it is probably easy to demonstrate that employees would pose a direct threat to patients if the employee was not vaccinated.
However, any policy that requires employees to receive the COVID-19 vaccine must comply with the Americans with Disabilities Act, Title VII of the Civil Rights Act of 1964, and other workplace laws. The Equal Employment Opportunity Commission has provided guidance to employees in Section K of What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws.
Note: See Sections K.5, K.6, and K.7 on when employers must provide a disability or religious exemption or a reasonable accommodation to employees.
More information is also available from the Society for Human Resource Management regarding what employers can do if workers refuse a COVID-19 vaccination and when employers can require COVID-19 vaccinations.
Lesions and other dermatologic manifestations have been observed as a potential symptom of COVID-19. These lesions can appear in several places, including the feet. The "COVID Toes" phenomenon requires further study.
In 2020, APMA worked closely with the American Academy of Dermatology (AAD) on its established COVID-19 registry, www.aad.org/covidregistry. Listen to this message from then-APMA President Seth Rubenstein, DPM, about the value of your participation.
APMA encourages its members to report cases of lesions on the feet associated with COVID-19 through this registry because it could have immediate and long-term strategic benefits for our profession.
“The emergence of so-called 'COVID Toes' is an opportunity for our profession to both contribute meaningful data as well as assist with research, publish papers, and collaborate with another medical specialty in education and research opportunities. Developing peer-to-peer relationships with the house of medicine can also open other doors for advocacy and education,” then-APMA President Seth Rubenstein, DPM, said. The principal investigator of the AAD Registry, Esther Freeman, MD, PhD, shared that, “We have seen a broad range of cutaneous manifestations in COVID-19, many of which involve the extremities and acral surfaces. We look forward to collaborating with our colleagues from APMA.”
The AAD COVID Registry is HIPAA-compliant and Institutional Review Board (IRB)-approved.
In early 2020, Tracey Vlahovic, DPM, reviewed dermatologic manifestations of viral diseases, including those associated with COVID-19. You can watch Dr. Vlahovic below as she discusses scientific literature related to dermatologic manifestations and how they are related to podiatric medicine.
Download a PDF of the presentation.
"COVID-19 and Dermatology: One Year in Review"
Editorial, Dermatol Clin, October 2021. Esther Freeman, PhD, and Devon McMahon, MD
"The spectrum of COVID-19-associated dermatologic manifestations: An international registry of 716 patients from 31 countries"
J Am Acad Dermatol, October 2020. Freeman E, et al.
"Foot Manifestations in a COVID-19 Positive Patient: A Case Study"
Clinical Correspondence, JAPMA, May 4, 2020. Michael Nirenberg, DPM, and Maria del Mar Ruiz Herrera
"Addressing the Question of Dermatologic Manifestations of SARS-CoV-2 Infection in the Lower Extremities: A Closer Look at the Available Data and its Implications"
Letter to the Editor, JAPMA, April 20, 2020. Rami Basatneh, DPM, and Tracey Vlahovic, DPM
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