Public Health Order 20-28

Sep 29, 2020 | Public Health Orders

PHO 28-28 & Appendix E

DENVER, CO [Update 07.16.2020]

Regarding Public Health Order 20-28: There is one small change in PHO 20-28 regarding the maximum number of people in your office, however the document creates confusion and holds inconsistencies throughout. We received clarification from CDPHE on July 15th that you are allowed up to 50 people or fewer in your office OR 50% maximum capacity of your office, whichever is less – including both staff and patients. You must still be able to maintain social distancing with the increase in the number of people in your office. Remember, previously you were only allowed 10 people in your office. So far, no other changes to PHO 20-28 impact the chiropractic office at the moment.

We encourage each chiropractor to become familiar with each of these documents listed above as they will impact your individual practices. To assist you in your review, below are a few key highlights of what is still required of chiropractors under Colorado’s “Safer at Home and in the Vast, Great Outdoors” order and Public Health Order 20-28:

  • Overall, all individuals are still encouraged to stay home whenever possible
  • Critical business, including chiropractors, may continue to operate, but are required to comply with the requirements set forth in PHO20-28.  PHO20-28 outlines critical businesses as defined in Appendix F, which states:

1.     Healthcare Operations, which includes: Hospitals, clinics, and walk-in health facilities […]

  • Further, chiropractic care has been identified in section III.K of PHO20-28 which defines limited healthcare settings.
  1. K. Limited Healthcare Settings means those locations where certain healthcare services are provided, including acupuncture (not related to personal services), athletic training (not related to personal services), audiology services, services by hearing aid providers, chiropractic care, massage therapy (not related to personal services), naturopathic care, occupational therapy services, physical therapy, and speech language pathology services. These individual services may only be performed with 50 or fewer people in a common business space at a maximum of 50% occupancy for the location, whichever is less, including both employees and patients, e.g. 5 chiropractors providing services to 5 customerswith Social Distancing Requirements in place of 6 feet distancing between customers receiving services. Employees must wear medical grade masks at all times, and patients must wear at least a cloth face covering at all times, except where doing so would inhibit that individual’s health, in which case reasonable accommodations should be pursued to maintain the safety and health of all parties, or if the service provided requires removal of the customer’s face covering. Services provided in Limited Healthcare Settings that are ordered by a medical, dental or veterinary practitioner, are subject to the requirements of Reference PHO 20-29; otherwise, the services are subject to the requirements of PHO 20-28. (emphasis added, updated 7.3.2020)
  • Appendix E applies to Limited Healthcare Settings, which includes chiropractic care. Directly below is a summary of Appendix E, however, this list is not inclusive. The full Appendix E is at the bottom of this email for your review.  Chiropractic offices must:
  • Provide services by appointment only, do not allow walk-ins or waiting for an appointment;
  • Continue to maintain 6 feet separation between clients and patients, when not directly performing service;
  • Those in the office, doctors and staff, who perform services with close, direct personal contact must wear medical grade masks and gloves; staff should wear gloves during any customer interaction;
  • Change gloves AND wash hands between every patient;
  • Clean and disinfect all shared equipment and tools between every patient;
  • Maintain detailed log of patient interactions to enable contact tracing if it becomes necessary. The log includes name, date, details of service performed and location of contact as well as the contact’s phone number;
  • Patients must wear at least a cloth face covering at all times and if a patient does not have a face covering, then a “disposable medical mask” can be provided;
  • Post signage for employees and patients on good hygiene and safety measures being taken;
  • Use remote alternatives whenever possible, such as drive-by supplement pick-up or telehealth;
  • Conduct symptom check for all patients, decline to provide services to anyone who has symptoms and refer them to their primary care physician;
  • Provide contactless payment options whenever possible;
  • Appropriately schedule patients so that providers have sufficient time to change PPE and ensure rooms and equipment can be cleaned and disinfected between each patient;
  • Use virtual waiting rooms when possible, i.e. parking lot waiting room
  • Maintain a plan to reduce or stop voluntary and elective procedures should a surge of COVID-19 cases occur in their region as determined by CHDPE;
  • Other important sections to note in PHO 20 28.
  1. Section II.I – Sets forth specific measures to implement for office protocol in general, measures related to your employees and measures regarding patients
  2. Section III.N – Social Distancing Requirements
  3. Section III. Q – “Vulnerable Individual”


Again, we encourage each of our member chiropractors to become familiar with the documents referenced in paragraph 1 above so that you can appropriately plan and implement your office and practice procedures to provided chiropractic care in compliance with Colorado’s “Safer at Home and in the Vast, Great Outdoors” orders.