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Mask Up - Are N95 Masks Still Required in Outpatient Clinics?

May 11, 2021
Compliance By Deborah Alexander, Director

With the first anniversary of the COVID-19 Public Health Emergency (PHE) declaration having just passed and vaccinations rolling out for healthcare providers and many patients, the outpatient therapy practice owners might be asking what type of face masks or protections are still required.




Many practices are continuing to assess the financial impact of providing additional Personal Protective Equipment (PPE) for staff from a supply chain perspective, along with meeting continued infection control requirements in regard to general housekeeping. This blog will outline the latest recommendations from the Centers for Disease Control (CDC) regarding types of face coverings and adding clarifications on the use of facemask as a crisis capacity strategy. The CDC posted guidance on their webpage, “Strategies for Optimizing the Supply of N95 Respirators” on February 10, 2021.

Outpatient healthcare providers are concerned about minimizing the COVID-19 transmission risk in the outpatient clinic while continuing to provide effective and safe in-person treatments. Exposures to transmissible respiratory pathogens can often be reduced or possibly avoided through engineering, administrative controls, and PPE. An example of engineering controls includes practicing social distancing in both the waiting rooms and treatment rooms. This strategy helps by keeping people apart from each other. Examples of administrative control include hand washing, sanitization of equipment and tools after use, or providing telehealth visits to be in compliance with capacity restrictions. The use of appropriate PPE is the focus of this blog.

What About a Critical Piece of PPE, N95 Masks, and Fit testing?

There is a range of choices when it comes to face coverings. N95 respirators are the PPE most often used to control exposures to airborne pathogens, though their effectiveness depends on proper fit and use. N95 respirators are intended for one-time use and require proper disposal upon use. When an outpatient clinic makes the decision to stockpile and utilize the N95 respirators based upon the clinical need, the clinic must follow OSHA guidelines for the Medical Evaluation and Fit testing, which is to be supported by policies and procedures related to the proper fit and use of N95 respirators. In situations where individuals do not appear to be positive for COVID-19, NIOSH-certified surgical masks can be utilized. Both types of facial coverings impose additional costs to practices, with N95 gasmasks being more costly.

When to Utilize N95 Respirators?

Considerations for use should be determined not just on cost but on the availability of the N95 and the at-risk complexity of patients being treated. It makes sense that if the N95 mask is the most effective mask and if it is in short supply, prioritization of the N95 should be saved for the most critically ill patients who have COVID-19. These patients would hopefully not be in the outpatient therapy clinic. The CDC provides guidance on facial coverings during low supply shortages.

The CDC lists several considerations related to the decision to use or not use the N95 mask. These include:

  • The number of patients receiving treatment with suspected or confirmed SARS-CoV-2 infection.
  • Evidence of ongoing transmission of COVID in the facility within the staff or patient population.
  • The incidence of COVID-19 in the community.
  • The availability of the N95 mask.

Regardless of whether the outpatient clinic decides to save the use of the N95 mask for suspected cases, an instance where a possible exposure is identified, or to use the N95 primarily, Medical Evaluations and Fit testing requirements are a requirement— not an option.

Requiring patients to wear masks is known as “source control.” Source control and implementing strategies to maintaining safe distances between patients are fundamental in reducing transmission risk in the outpatient clinic.

In healthcare settings, facemasks promote these general purposes:

  1. As PPE, facemasks supplement protection of the nose and mouth from exposure to splashes, sprays, splatter, and respiratory secretions (e.g., for patients on Droplet Precautions). When used for this purpose, facemasks should be removed and discarded after each patient encounter.
  2. When recommended for source control while they are in the healthcare facility, to cover one’s mouth and nose to prevent the spread of respiratory secretions when they are talking, sneezing, or coughing. When used for this purpose, facemasks are usable until they become soiled, damaged, or hard to breathe through. Wearers should immediately discard them after removal.

In summary, the outpatient provider has choices for the use of facial coverings. When the clinic is continuing to screen patients with a short history questionnaire regarding any recent exposures, taking temperatures, and noting increased vaccination percentages amongst the patient populations, the exposure risk of anyone with active COVID-19 coming into the clinic for treatment is low. The outpatient clinic should continue to follow the CDC and state and local health department requirements on mask-wearing for patients and staff. The use of an N95 mask is not mandated in the absence of treating patients who are not currently infected with the COVID-19 virus and who do not require Droplet Precautions. Keep in mind, N95 respirators could be required to provide respiratory protection, regardless of COVID-19, and the requirement to conduct Fit Testing and Medical Evaluations remains.

How Can LWCI Help?

  • LWCI offers a customizable OSHA Environmental, Health, and Safety Compliance Manual which contains policies and procedures. This manual, and other products to help maintain your policies and procedures, can be found at the LWCI Store.
  • LWCI’s OSHA Plan contains a COVID-19 specific chapter, which supports a business’ compliance to respond to the OSHA National Emphasis Program survey and response audits.

If you have questions regarding infection control requirements, OSHA guidelines, or implementing OSHA policies and procedures, contact Deborah Alexander at 717-213-3122 or email

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