May 1, 2020
Take Precautions Against Cybersecurity Threats

Almost all Registered Psychotherapists who are still providing essential services during coronavirus isolation are doing so remotely, using electronic methods. This means that an increased number of RPs may be vulnerable to scams and other cybersecurity threats.

Insurance provider HIROC recently issued the following alert regarding cyber threats to health care providers’ information security, client confidentiality and privacy:
Healthcare organizations have, unfortunately, become a popular target for scammers and fraudsters during the COVID-19 pandemic. A number of international law enforcement agencies (including the FBI and CSIS), financial institutions, and cybersecurity centres have recently issued warnings related to an increased risk and incidence of social engineering scams directed at the healthcare sector.

Here are a few examples of social engineering scams:
  • Criminals impersonating employees or vendors requesting changes to deposit bank accounts
  • Fake COVID-19-themed emails coercing staff to click on malicious links that then download malware or ransomware
  • Emails requesting users to log into their banking website to update information. These emails contain links to malicious websites that have been set up to look like legitimate sites (e.g. financial institutions such as banks and credit unions, and vendor websites).

With this increase in risk, it is important that healthcare providers and organizations develop good security habits and remain vigilant and suspicious of all emails.

Cybercriminals have become very sophisticated and are using “spoofing” functionalities that make fraudulent emails look virtually identical to legitimate emails sent from internal systems.

HIROC advises:
 Scrutinize emails for unusual behaviour, language, and circumstances
 Verify the validity of email requests before taking any actions, including, but not necessarily limited to the following:
  • Changing banking details
  • Processing urgent payments or online banking
  • Logging into websites
  • Clicking links
  • Opening unverified attachments

HIROC recommends health care providers and organizations adopt robust verification processes and practices, such as secondary sign-off on payment detail changes, and phone verification using known contact numbers. 
Does Your Insurance Cover Cybersecurity Threats?

When considering how your practice may be vulnerable to data breaches, social engineering scams or other fraudulent behaviour, take time to review the terms of your practice insurance. Particularly if you are new to electronic practice, contact the brokerage or professional association you purchased your insurance from to find out if you have any vulnerabilities in your coverage.  
Mandatory Reports During the Pandemic

The duty for registrants and their employers to file mandatory reports does not change while Ontario is in a state of emergency due to the covid-19 pandemic. While certain deadlines, e.g. responding to a complaint or completing QA requirements, can be extended for reasonable cause, the requirement to file mandatory reports, e.g. to report sexual abuse by a regulated health professional, remains in place. 
Planning for Transition to In-Person Practice: Implementing Infection Prevention and Control Practices

In light of the government’s April 27 release of their framework for Reopening Ontario after COVID-19 , CRPO has turned its attention to assisting registrants in early-stage planning for a transition back to in-person practice.

While dates have not been specified for the start of the re-opening, key messages from government are as follows:
  • The government has started planning for the easing of emergency orders and a gradual return to normal.
  • Planning is taking into consideration epidemiological modelling and evidence, health system capacity, public health measures to contain spread, and availability of PPE to support non-urgent care. 
  • Each step will be informed by public health advice, the best available evidence and situational awareness of COVID-19 in Ontario.

It is too early to tell when measures such as the Chief Medical Officer of Health’s Directives and the government’s  Emergency Orders will be eased or lifted and when non-urgent and elective health services will resume. The government has committed to continuing to work with health system partners to provide open and transparent communications about what measures will be taken and to endeavour to provide advance notice, where possible, to affected stakeholders.

CRPO is in consultation with government and will be working with the other regulated health colleges to develop and share more guidance related to return to work in advance of the lessening of restrictions. These will be shared as they become available.

We do know that a key part of the preparation that health care providers need to consider in advance of any easing of restrictions is determining what best practice will be for infection prevention and control post COVID-19. 

While this list is not exhaustive, it is provided to give RPs a sense of the issues and types of measures that will be required:

Before Appointments
  • client appointments should be scheduled to limit the number of people gathered in waiting areas
  • seats in waiting areas should be spaced to maintain a minimum physical distance of two metres (note that household contacts are not required to separate)
  • you may wish to employ alternative solutions to waiting in the office, such as asking clients to wait in vehicles and text messaging or calling when you are ready to see them
  • non-essential items such as magazines, toys and remote controls should be removed from client waiting areas
  • protection for support staff (e.g., a physical barrier at reception, use of masks) should be considered
  • clients should be asked at time of booking if they have been experiencing symptoms of illness consistent with COVID-19; anyone who has symptoms at the time of booking should be offered a virtual visit or be scheduled for a later time
  • RPs who use body work as part of their practice may need to consider the use of personal protective equipment or delaying in-person care using this modality until the time when infection is not an issue

At Appointments
  • where possible, therapy rooms should be furnished to allow physical distancing between RPs and clients
  • the use of masks by staff and clients should be considered generally and particularly in situations where adequate physical distancing is difficult
  • all clients should be asked to self-screen and, upon arrival, be screened by you or staff for visible symptoms consistent with COVID-19. Anyone who presents at an appointment with symptoms should be asked to wear a surgical/procedure mask and consideration should be given as to whether the appointment should be cancelled
  • RPs whose practice includes the use of materials that cannot be sanitized (e.g., clay) may need to move to single-use materials or delay using these kinds of materials until the risk of transmitting COVID-19 is reduced

After Appointments
  • common areas and other high-touch surfaces and objects (e.g., reception counters, chairs and seating areas, doors, handrails and objects or equipment used in therapies) should be cleaned and disinfected after each use with a hard surface area cleaner approved by Health Canada
  • all RPs and any support staff must practice effective hand hygiene after each client, washing their hands with soap and water or an alcohol-based hand sanitizer approved by Health Canada 
  • wherever possible, RPs and staff should refrain from sharing phones, desks, offices and other tools and equipment

In addition, there are resources that RPs should consult in order to understand the scope of what is required for infection control, what steps they will need to take prior to resuming in-person practice and what resources they may need to do so:

Getting your workplace ready for COVID-19 – this general resource from the World Health Organization provides advice on ways to prevent the spread of COVID-19 in your workplace and how to manage COVID-19 risks when organizing meetings.

COVID-19 Guidance: Primary Care Providers in a Community Setting – while this resource is geared more toward primary care that requires physical contact, it has useful information related to managing in-person care and essential visits, active and passive screening of clients and occupational health and safety.
Infection Prevention and Control for Clinical Office Practic e this comprehensive resource was developed for clinical care spaces, however the infection prevention and control practices it outlines could be useful for RPs looking for practical tools to guide their efforts.

Risk-informed decision-making guidelines for workplaces and businesses during the COVID-19 pandemic – this page provides a framework for risk-informed decision making about public health actions for workplaces/businesses during the COVID-19 pandemic. It includes a practical framework for assessing and strategizing around mitigating risks. RPs in private and in group practices could use this tool to develop strategies that will allow you to practice safely. 

Hand Hygiene – this page provides links to signage, training videos and other hand hygiene related resources.

Non-medical masks and face coverings: How to put on, remove and clean – you may wish to wear a mask, or ask your clients to wear one, once you return to in-person practice. These pages provide guidance about the use of and limits to the use of non-medical face masks.

Recommended Steps for Putting On and Taking Off Personal Protective Equipment – for RPs who work in settings where they may be asked to work in areas where there are suspected cases of COVID-19 (e.g., in a hospital), this resource is a practical, step-wise set of instructions on using personal protective equipment 

Hard-surface disinfectants and hand sanitizers (COVID-19): List of hand sanitizers authorized by Health Canada - These pages list products that have been deemed safe and effective in cleaning and sanitizing commonly touched areas.

CRPO is aware that there is a real potential for information overload for you as health care providers. As the pandemic continues to evolve and more resources are being made available, we have posted a list of resources that may be particularly useful to you in managing your practice. This is not an exhaustive list; you are encouraged to access trusted sources in your region, your Public Health Unit for example, and to monitor both the provincial and federal government sites for up-to-date information. Access our list of resources on our FAQ for RPs on COVID-19 web page, and look under Government Notices & Resources.
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