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Guidance for Potential Patient Exposure to COVID-19 by HCP in the Outpatient Setting

Posted/Updated on 2/10/21 2:00 PM

Depending on the level of community spread in your area, the likelihood of one of your healthcare providers becoming infected with COVID-19 may be substantial. To keep your staff and patients safe, be sure that you have implemented pandemic infection prevention and control measures as per CDC guidance.

If a healthcare provider (HCP) tests positive for COVID-19 and there was potential patient exposure, notification to patients who had prolonged close contact (within 6 feet for at least 15 minutes) to the provider may be recommended. Contact your local public health department to ensure locale-specific directives are followed.

As per the CDC, the following time periods and criteria should be considered when determining which patients may have potentially been exposed: ¹

  • If the provider had COVID-19 symptoms, the provider is considered potentially infectious beginning 2 days before symptoms first appeared until the provider meets criteria to discontinue Transmission-Based Precautions or Home Isolation.

  • If the provider did not have symptoms, collecting information about when the provider may have been exposed could help inform the period when they were infectious.

  • If an exposure is identified. The provider should be considered potentially infectious beginning 2 days after the exposure until the provider meets criteria to discontinue Transmission-Based Precautions or Home Isolation.

  • If the date of exposure cannot be determined. For the purposes of contact tracing, it is reasonable to use a cutoff of 2 days before the specimen testing positive for COVID-19 was collected as the starting point, continuing until the criteria to discontinue Transmission-Based Precautions or Home Isolation are met.

The CDC recommends contact tracing for exposed patients and visitors who had prolonged close contact with the infected HCP during these time periods. This process includes identifying, notifying, and following up on potentially exposed individuals. Create a contact tracing plan in collaboration with your local or state health department and be sure you have a clear understanding of your role in this process. Also be sure to protect the confidentiality of the individuals affected.

If you will be involved in the contact tracing process, the CDC provides the following risk assessment guidance to identify patients at higher risk for transmission to aid in your evaluation and testing prioritization: ¹

  • Facemask use by the patient – Mirroring the risk assessment guidance for healthcare personnel, patients not wearing a facemask would likely be at higher risk for infection compared to those that were wearing a facemask.

  • Type of interaction that occurred between the patient and infected provider – An interaction involving manipulation or prolonged close contact with the patient’s eyes, nose, or mouth (e.g., dental cleaning) likely poses higher risk of transmission to the patient compared to other interactions (e.g., blood pressure check).

  • PPE used by infected HCP – HCP wearing a facemask (or respirator) and face shield that extends down below the chin might have had better source control than wearing only a facemask. Note that respirators with exhalation valves might not provide source control.

  • Current status of patient – Is the patient currently admitted to a hospital or long-term care facility?  These individuals, if infected, can be at higher risk for severe illness and have the potential to expose large numbers of individuals at risk for severe disease.

Ethical Considerations

In determining your duty to inform those patients or visitors who may have been exposed in your office there are many factors to consider. As the CDC notes, patients who live in areas with higher levels of community transmission should be vigilant to any signs or symptoms of COVID-19 in general, as exposure risk is heightened.¹ If you practice in an area with less community transmission, your duty to notify patients may be higher, however, the local health departments availability to assist in this process may be higher as well. Contacting your local and state health department is a beneficial step in determining your role in the notification process after potential patient exposure has been identified. Understanding the unique risks to the patient population you serve is important as well and should be considered.

Notification of Exposure Guidance

The recommended method for exposure notification to patients is via telephone. While exposure notification letters can be used, these may result in notification delays as well as leaving patients with multiple questions and anxiety. A phone call allows for notification along with education and an ability for patients to ask questions. This education may include facts about COVID-19, signs and symptoms to monitor, and potential isolation recommendations, if applicable. It also allows for individualized dialogue based on the patient’s unique health history. In the event a patient has underlying health conditions, other risk factors, or reports symptoms of COVID-19 during the call; you may wish to recommend testing. This referral can be made during the call along with guidance on local testing center locations. The CDC offers a detailed exposure notification guide to assist in this process including verbiage for contact tracing conversations. As with any protected health information, always protect the confidentiality of your health care worker and be sure to train staff on the confidential nature of this information.

Additional Resources/Links



¹ Clinical Questions about COVID-19: Questions and Answers. CDC’s COVID-19 Website. Updated August 4, 2020. Accessed August 13, 2020

Topics: COVID-19

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The information provided on this site offers risk management recommendations and resource links. The information does not constitute a legal opinion, nor is it a substitute for legal advice. Legal inquiries about this topic should be directed to an attorney. NORCAL Group makes no representation regarding compliance with state or federal law by offering these resources. These documents and links are provided for your convenience and reference only, and the provision of these materials does not mean NORCAL Group is affiliated or associated with these organizations.