Preventive Tips for Managing COVID-19 in the Clinic
Dear member,

We are living through novel and anxiety-inducing times as a result of serious public health concerns throughout Canada due to the emergence of the novel coronavirus (SARS-CoV-2) that causes COVID -19. As a service to the members of the CVMA, we take this opportunity to offer some general guidance on numerous issues that may arise in the conduct of your veterinary practice.
CREDIBLE INFORMATION SOURCES

It is critical that all members make decisions in response to the COVID-19 pandemic with reference to only reliable and credible sources. As you will have noted, the fast-pace at which the virus has been transmitted has given rise to a number of statements in social media and elsewhere which are, at a minimum, suspect and, in some cases, patently false. As a healthcare provider, the veterinarian will be looked to by clients and members of the public for guidance and advice on issues that arise in relation to animal ownership and companionship. 

Given that your clients will be relying upon the advice you provide, it is critical from a risk-management perspective for your practice, to ensure your knowledge of the current status is accurate and up-to-date. This is not a time to speculate on a response to an inquiry – if one is uncertain of the accurate information, then no opinion should be advanced and a referral to another source should be made. The environment in which the animal hospital operates is quickly changing with new directives from public health authorities, governments and veterinary provincial regulators.
Reputable sources include human medical expert organizations such as:

Reputable animal health organizations include:
At the time of this publication, there is no vaccine to protect against COVID-19. The U.S. Centers for Disease Control and Prevention (CDC) advises that non-pharmaceutical interventions (NPIs) will be the most important tools. There are three categories of NPIs:
  • Personal NPIs, which include personal protective measures such as washing hands using an appropriate technique or the liberal use of hand sanitizers;
  • Community NPIs, which include social distancing designed to keep people who are sick away from others; and
  • Environmental NPIs, which include surface cleaning measures.

Each clinic will have to determine which NPIs are appropriate for its practice.
HUMAN RESOURCE MANAGEMENT

Veterinary practice owners will be at the forefront dealing with a multitude of COVID-19-related issues in their clinics, which could cause significant business disruptions. In particular, there are a plethora of employment law related issues that need to be thoughtfully considered and appropriate strategic plans implemented.

The following concrete steps can be taken by veterinary hospital owners before the potential wider outbreak warned by Canada’s Public Health Officer. If a further outbreak occurs, veterinary practice owners and hospital managers should consider the following potential employment issues (including business continuity) that may arise and the relevant legal considerations:

i. remind employees of respiratory etiquette and hand hygiene; providing the necessary supplies (soap and/or hand sanitizer) and instruction on appropriate technique;

ii. inform s ick and symptomatic employees they must stay at home and are not permitted into the work premises ;

iii. perform routine environmental cleaning of the clinic; especially between client visits to examination rooms;

iv. advise employees to take steps before travelling such as reporting their travel locations to the clinic owner or manager;

v. consider restricting business travel to certain countries or regions acknowledging that some countries have “closed their borders” or have restricted travel to only “essential visits” for commercial purposes;

vi. encourage employees to inform the clinic owner or manager if they are undergoing testing for COVID-19, particularly if there has been contact with others at the workplace – such information is to be treated confidentially, respecting the privacy of the employee;

vii. encourage employees to inform the clinic owner or manager if they have a sick family member at home with COVID-19 or have otherwise been exposed to the virus, once again ensuring privacy;

viii. inform employees that some people may be at higher risk for severe illness, such as older adults or those with chronic medical conditions or autoimmune compromises;

ix. encourage employees that may be vulnerable and may be at higher risk for COVID-19 adverse health complications to inform the clinic owner or manager, so an informed decision on whether additional precautions should be considered, if applicable, on a case-by-case basis;

x. cross-train employees to perform essential functions in case of workplace absences of others, obtaining the consent of the employees if such additional training may result in an untended arbitrary change in the job description of the relevant employee;

xi. remind employees of cyber risk related to COVID-19, including not becoming a victim of COVID-19 phishing email attacks which are on the rise;

xii. consider whether flexible work hours ( e.g. , staggered start times and/or shifts), remote work, or other off-site arrangements would be acceptable to the practice (acknowledging that this is challenging for the veterinary clinic which relies on less-than-portable diagnostic equipment and the need to secure restricted medications), and if necessary, upgrading and testing technology to deal with remote work arrangements if required;

xiii. reach out to key suppliers to ensure the business will have uninterrupted goods and services during any outbreak, such as regularly-used medications and other inventory;

xiv. consider cancelling and re-scheduling client information sessions including dog training classes or grooming services;

xv. create or update human resources policies, including statutory and non-statutory leaves of absence policies and legal requirements, practice continuity plans and pandemic response plans, including who in the chain of command can make a decision to close the practice; and

xvi. assess whether, in case of an outbreak, the practice has and will continue to have sufficient inventory and supplies, including from a health and safety perspective ( e.g. , tissues, no-touch disposal receptacles, soap and water, surface cleaning supplies, disposal wipes and hand sanitizer).
Some common scenarios a practice owner may encounter include the following:

  • Employee attends the clinic while ill. Employees who shows up in the clinic appearing to have acute respiratory symptoms (e.g., cough or shortness of breath) should be separated from other employees and/or, if appropriate, sent home without delay. As a preventive measure, administrative staff and technicians should be advised to not report to work if they feel ill and merely let office personnel know of the planned absence.
  • Employee refuses to work for safety reasons, employee returns from travel from a region that has reported COVID-19 cases and/or evidence of community transmission, or employee informs the clinic owner or manager that s/he or a family member at home is undergoing testing for COVID-19. While this will require a case-by-case determination, key legal considerations for employers will be occupational health and safety legislation, employment standards legislation and public health guidance from reputable sources. Context will be very important. A region that has thousands of community transmission cases may be different from a region with only one reported case that is not from community transmission. An employee with a high number of face-to-face interactions may warrant different considerations than an employee that has limited face-to-face interactions. Ultimately, the clinic is responsible pursuant to provincial occupational health and safety laws, to provide a safe workplace. If the clinic owner or manager is made aware of the increased risk one employee presents to the rest of the hospital team, then the relevant employee should not be permitted in the clinic and seek access to employment insurance benefits if possible.
  • Employee discriminates against another employee on the basis of race or other prohibited grounds. All employers generally have an obligation to maintain a discrimination-free workplace. Clinic owners must deal with any discriminatory behaviour, such as inappropriate and racist comments relating to a co-workers ethnicity, from employees promptly and firmly. 
  • Significant absences in the workforce. Clinic owners should consider how they would deal with a significant number of absences, including for reasons of voluntary self-isolation or mandatory quarantine. Options include asking employees to work overtime and hiring temporary employees with appropriate short-term employment contracts to mitigate risk.
GENERAL VETERINARY BUSINESS CHALLENGES

There are a number of additional challenges that will face veterinary clinics throughout Canada as we move ahead:

Effective Risk Management Strategies
One should not assume each client attending the clinic is well-informed about COVID-19. While media attention has been widespread, it is prudent for the clinic to take proactive steps in client communications outlining the steps the clinic has taken to provide a safe professional services environment and invite clients who are ill or in self-isolation for any reason to not attend the premises in favour of a telephone discussion - take an appropriate history and provide advice if one can do so without a physical examination of the animal. One does not want to have to defend the clinic and its operations from potential claims that a client or other attendee contracted the virus as a result of improper conduct or warnings from the clinic. While such a claim is remote, it is best to plan ahead in this regard. So long as the clinic has taken reasonable steps to safeguard the safety of those attending the clinic, then a successful claim in this regard is not likely.

Fulfilling Terms of Engagement
As mentioned above, ensuring a reliable supply chain for inventory is important; in the unlikely event of government-ordered closures of clinics, a sound relationship with a human pharmacy may be needed to ensure necessary medications are available to clients.

Accounts Receivable Management
In the event of a prolonged absence from a closed place of employment, clients may face some economic hardships. Consideration needs to be given to an effective accounts receivable strategy including the granting of credit on documented and reasonable terms.

Alternative Financial Arrangements
Some clinics will, no doubt, be experiencing slow-downs in client visits as a result of suggestions that “staying home” is an appropriate “social distancing” strategy. This may give rise to a compromised financial condition. One should reach out to landlords, equipment lessors, and banks to discuss alternative, temporary payment terms in order to assist in this temporary slow down. Most creditors will be pleased to offer less robust repayment terms.
The CVMA hopes these comments are of assistance to you. Inquires can be directed to Dr. Shane Renwick, CVMA Manager of National Issues at srenwick@cvma-acmv.org .
The CVMA wishes to express its thanks to Douglas Jack and James Fu of the national law firm of Borden Ladner Gervais LLP for their contributions to this communiqué.
You are receiving this message as a member of the Canadian Veterinary Medical Association (CVMA). The CVMA is the national and international voice for Canada’s veterinarians, providing leadership and advocacy for veterinary medicine.