RHC Specific
Infection Control, Cleaning Logs & PPE Expectations
🧾 Applies to: Anyone who works on-site at an RHC location or other clinical office (NPs, techs, front desk in clinic, anyone using treatment rooms).
Telehealth-only staff should still skim so they understand expectations when they are on-site.
Why Infection Control Matters
As an RHC, we’re responsible for keeping our clinical spaces safe and clean for clients and staff. Infection control isn’t just for “medical” procedures—it includes any time clients share physical spaces, equipment, or surfaces.
This lesson explains:
- Basic infection control expectations
- How and when to clean treatment areas
- How to complete cleaning logs
- When and how to use PPE (personal protective equipment)
Standard Precautions
We follow standard precautions, which means:
- Treat all blood and body fluids as potentially infectious.
- Perform hand hygiene:
- Before and after each client encounter
- After removing gloves
- After contact with potentially contaminated surfaces
- Use gloves and other PPE when there is a risk of contact with blood, body fluids, or contaminated surfaces.
Hand hygiene:
- Prefer soap and water when hands are visibly soiled.
- Alcohol-based hand rub is acceptable for routine hand cleaning between clients when hands are not visibly dirty.
Cleaning & Disinfection of Client Areas
For all RHC/clinic rooms used for client care:
Between each client:
- Wipe down:
- Treatment chairs/beds/exam tables where clients sit or lie
- High-touch surfaces (desk area where client rests arms, commonly touched handles or switches if used)
- Use the approved disinfectant and follow contact (wet) time on the label.
Daily:
- Clean floors as required for that site.
- Wipe down:
- Shared equipment
- Door handles
- Light switches
- Front-desk surfaces
Weekly (or per site protocol):
- Deeper cleaning per site schedule (e.g., baseboards, less frequently touched surfaces).
Check your site-specific guidance for exact daily/weekly tasks—those may be listed on the cleaning log itself.
Cleaning Logs – How to Use Them
For each RHC clinical area, we maintain cleaning logs to show that we’re consistently following our cleaning schedule.
On the log, you’ll typically see:
- Date
- Area/Room
- Task(s) (e.g., “Between-patient surfaces,” “End-of-day cleaning”)
- Initials of person who completed the task
Your responsibilities:
- Find the log for your room/area at the start of your shift.
- Each time you complete a cleaning task (e.g., end-of-day cleaning), initial and date the log.
- If you realize something was missed, clean it and document it—do not back-date.
If you’re not sure where the log is kept or how to fill it out, ask your supervisor or the site lead.
PPE (Personal Protective Equipment) Expectations
PPE can include:
- Gloves
- Masks
- Eye protection (if needed for certain tasks or splashes)
- Gowns (rare in our setting, but may apply for specific tasks)
General expectations:
- Gloves:
- Wear when there is a risk of contact with blood, body fluids, or contaminated surfaces.
- Change between clients and wash or sanitize hands after removing gloves.
- Masks:
- Follow current site policy (this may change based on public health guidance or client population).
- Use when required by policy, or when a client requests it and it is reasonable to do so.
- Other PPE:
- Use as indicated by specific procedures or protocols.
PPE is not a substitute for hand hygiene or proper cleaning—it’s an added layer of protection.
Waste & Sharps
If your role involves handling sharps or medical waste:
- Dispose of needles and other sharps immediately in approved sharps containers—never recap.
- Dispose of contaminated materials in designated waste containers according to site procedures.
- Do not overfill sharps containers; alert the appropriate person when they are near capacity.
If you experience an exposure (e.g., needle stick, blood splash):
- Follow the exposure protocol immediately (wash area, report to supervisor, seek medical evaluation).
- Complete an incident report.
What This Means for You as Staff
Infection control at our RHC and clinic sites means you:
- Wash/sanitize your hands regularly, especially between client encounters.
- Clean and disinfect surfaces according to the schedule and document it on cleaning logs.
- Use gloves and PPE when indicated.
- Handle sharps and waste safely and according to policy.
- Ask questions if you’re unsure what is required in a specific room or situation.
Labs, CLIA, Standing Orders & Nursing Protocols
🧾 Applies to: NPs, clinical staff, field techs, and any staff who touch lab-related workflows or carry out tasks under orders/standing orders.
Why This Matters
As an RHC, we may:
- Perform CLIA-waived tests in-house
- Collect specimens for outside labs
- Use standing orders or protocols so techs and support staff can do certain tasks safely and legally
Everyone involved in these workflows must understand who can do what, under whose authority, and how to handle specimens correctly.
CLIA & On-Site Testing (High Level)
CLIA (Clinical Laboratory Improvement Amendments) sets rules for lab testing. We operate under a CLIA-waived certificate for certain simple tests (if/when applicable at a given site).
Examples of CLIA-waived tests might include (depending on site set-up):
- Point-of-care glucose
- Urine dipstick
- Pregnancy Tests
Key points for staff:
- You may only perform tests that:
- Are listed as approved for our site and
- You have been trained and signed off to perform.
- Follow the test manufacturer’s instructions exactly:
- Sample collection
- Timing
- Reading results
- Quality control checks (if required)
- Document results in the EHR or on designated forms exactly as you’re trained.
If you are unsure whether we are authorized to perform a specific test, do not do it until you confirm with your supervisor or NP.
Standing Orders & Nursing/Tech Protocols
What is a standing order?
A standing order is a written protocol from an NP or other authorized provider that allows designated staff (nurses, techs, etc.) to perform specific tasks without getting a new individual order every time.
For example, a standing order might allow a trained tech to:
- Take and document vitals for all RHC clients
- Perform certain screenings (e.g., standardized questionnaires)
- Run a specific CLIA-waived test when certain criteria are met
Your responsibilities under standing orders:
- Know which standing orders apply to your role.
- Only do tasks you are:
- Explicitly allowed to do
- Trained and competent to perform
- Follow the protocol exactly:
- When to do the task
- How to document it
- When to notify the NP or clinician about abnormal findings
If something falls outside a standing order (e.g., a new or unusual situation), you must get a direct order or instruction from the NP/clinician.
Scope & Staying In Your Lane
Under RHC workflows:
- NPs and other licensed providers are responsible for diagnosing, ordering tests, and making treatment decisions.
- Techs, case managers, and other staff support by:
- Gathering data
- Performing permitted tests or procedures
- Carrying out follow-up tasks within their scope
You should never:
- Interpret lab results as a diagnosis if that is not your scope.
- Change treatment plans or medications.
- Perform a test or procedure you are not authorized or trained to do.
When in doubt, ask the NP or supervisor before proceeding.
What This Means for You as Staff
Labs, CLIA, and standing orders in the RHC context mean you:
- Only perform tests and procedures you are trained, authorized, and signed-off to do.
- Follow collection, labeling, and storage procedures carefully.
- Use standing orders as written—not as general permission to “do whatever seems helpful.”
- Communicate findings and concerns promptly to the NP or supervising clinician.
Emergency Transfer Procedures & EMTALA Awareness
🧾 Applies to: Anyone working in or supporting RHC clinical sites; telehealth clinicians should also understand the basics for when a client might need a higher level of care.
We Are Not an ER, But We Still Have Duties
Our RHC and clinics are not emergency rooms. We are not equipped to handle all emergencies on-site.
However, we do have a duty to:
- Recognize serious medical or psychiatric emergencies
- Respond quickly and appropriately
- Arrange safe transfer to a higher level of care when needed
When to Consider Emergency Transfer
Examples (not exhaustive):
- Chest pain, shortness of breath, or signs of heart attack
- Stroke-like symptoms (sudden weakness, slurred speech, facial droop)
- Severe allergic reaction (trouble breathing, swelling of face/lips)
- Acute, severe injuries or bleeding
- Severe changes in mental status (confusion, unresponsiveness)
- Imminent risk of suicide or serious harm to others
- Overdose or suspected poisoning
If you believe someone is experiencing a potentially life-threatening condition:
Your first job is to activate emergency services (usually 911), not to diagnose.
Steps for Emergency Transfer (On-Site)
- Call 911 immediately.
- Provide:
- Clinic address and location
- Client’s name and age
- What you observed
- Any immediate known medical information (if needed)
- Provide:
- Stay with the client if it is safe to do so.
- Keep them comfortable and calm.
- Do not provide treatment outside your training/scope.
- Notify internal leadership.
- Inform the NP, on-site lead, and/or supervisor as soon as possible.
- Prepare basic information for EMS/hospital:
- Recent vitals (if available)
- Medications list (if accessible)
- Summary of what happened and what the client reported
- Document the event.
- In the clinical record
- With an incident report, if criteria are met
Telehealth-Related Transfers
For telehealth emergencies (where client is not physically on-site):
- Follow the Telehealth Emergency Procedures lesson:
- Confirm location
- Contact 911 or local emergency services in the client’s area if there is imminent risk
- Document and report as required
EMTALA – Awareness Level
You may hear references to EMTALA (Emergency Medical Treatment and Labor Act).
You don’t need the legal details, but you should know:
- EMTALA is a law that requires hospital emergency departments to provide screening and stabilizing treatment to anyone who comes seeking emergency care, regardless of ability to pay.
- We are not an emergency department, but:
- When we call 911 or arrange transfer to a hospital, we are handing off to a system that has EMTALA obligations.
- Our role is to clearly communicate the situation and support a safe transfer.
We do not refuse emergency help to someone because of insurance or ability to pay. We focus on safety first and work out the rest later.
What This Means for You as Staff
Emergency transfer responsibilities mean you:
- Take potential emergencies seriously and act promptly.
- Know where emergency numbers, clinic address, and key info are posted.
- Call 911 when needed, then inform internal leadership.
- Document clearly and complete incident reports after serious events.
- Understand that we partner with hospitals and EMS to provide higher-level care when needed.
You are not expected to be perfect in the moment—you are expected to move toward safety, communication, and documentation.
RHC Visit Requirements & “Incident-To” Roles
🧾 Applies to: All clinicians and support staff whose work is tied to the RHC program (including telehealth clinicians tied to the RHC NPI).
What Is an RHC Visit (Encounter)?
In simple terms, an RHC visit is:
A qualifying visit between an eligible provider and a client, delivering a covered service, billed under the RHC structure.
You don’t need to know every billing detail, but you should understand:
- There must be a documented clinical service (not just a quick check-in).
- The service has to fall within what payers recognize as an RHC visit.
- Eligible providers and specific rules vary by payer and program—our billing/operations team handles the technical side.
Your job is to:
- Provide good care
- Document clearly
- Understand how your role supports the billed encounter
Documentation for RHC Visits
For RHC-related services, documentation needs to:
- Clearly state why the client was seen (reason for visit).
- Show what you assessed and addressed (symptoms, history, context).
- Describe the interventions or treatment provided.
- Include assessment, diagnosis (if applicable), and plan.
- For time-based services (if used), reflect the time and work actually done.
If the RHC encounter is a mental health visit, documentation must still:
- Meet behavioral health standards
- Meet any RHC-related payer expectations for that type of visit
“Incident-To” / Team-Based Work (Concept)
In the RHC context, you’ll often hear about tasks done “incident to” a provider’s services.
At a practical, staff level:
“Incident-to” means tasks that are done under the direction/order of a provider and are part of the overall service, rather than separate billable visits on their own.
Examples:
- A tech taking vitals and standardized measures before an NP or therapist visit
- A tech running a CLIA-waived test that an NP ordered
- A staff member providing certain education or support follow-up per a provider’s plan
Key points:
- These tasks are not usually billed as separate visits—they support the main encounter.
- The billing provider (often an NP or designated clinician) is ultimately responsible for the overall service.
- You must:
- Work within your scope
- Follow standing orders or direct orders
- Document clearly what you did
Roles & Responsibilities Under the RHC Umbrella
Providers (NPs, clinicians aligned with RHC):
- Conduct RHC-eligible visits
- Diagnose, prescribe, and order tests as allowed by their license
- Oversee the clinical work of support staff related to RHC encounters
- Ensure documentation supports what is billed
Techs, Case Managers, Field Staff:
- Carry out tasks under orders/standing orders (within scope)
- Gather data (vitals, screening tools, histories)
- Provide education or support as instructed
- Document their piece of the work clearly
- Communicate important findings to providers
Front Desk/Administrative Staff:
- Schedule RHC-related visits correctly in the system
- Use correct insurance and program information
- Direct safety or billing concerns to the appropriate person
What This Means for You as Staff
Understanding RHC visit requirements and “incident-to” work means you:
- Know that some or many of your services (especially if you’re Ohio-licensed) are being billed under the RHC umbrella—even if you are doing therapy.
- Appreciate that documentation matters for clinical, legal, and billing reasons.
- Understand that “incident-to” is about team-based care: your work is part of a bigger visit, not a stand-alone billable service.
- Stay within your scope and follow orders/standing orders rather than improvising.
- Ask supervisors or operations/billing leadership when you’re unsure how a service is being billed or what is expected.