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Face Coverings and Disability Accommodations

California Public Health officials issued guidance on June 18 that mandates the use of masks or face coverings in most public settings statewide to help slow the spread of COVID-19. The guidance was amended on June 29 to clarify that children under two years old are exempt from wearing face coverings.

Exemptions to face-mask mandate

Guidance exemptions include individuals:

  • Who have a medical condition
  • With a mental health condition or disability that prevents wearing a mask.
  • Who are hearing impaired.
  • Communicating with a person who is hearing impaired where the ability to see their mouth is essential for communication.

CDC guidance

The Centers for Disease Control and Prevention (CDC) offers guidance regarding individuals who could be exempt from wearing a face covering, including people who have:

  • A respiratory disability such as asthma, COPD, or cystic fibrosis.
  • PTSD, severe anxiety, or claustrophobia.
  • Sensory issues, such as autism.
  • Limited mobility in hands, wrists and fingers such as cerebral palsy.

Make reasonable accommodations

The Americans with Disabilities Act does not have any rules that specifically address face coverings in public; however, under Title III of the act, businesses must still consider reasonable modifications for people with disabilities.

Dental practices can provide reasonable accommodations by:

  • Asking patients to wait in the car until it is time for treatment.
  • Scheduling a patient for the end of the day.
  • Keeping patients without a face covering separated from other patients.
  • Allowing a patient to wear a scarf, loose face covering or full-face shield instead of a mask.
  • Offering a tele-dentistry appointment to determine a treatment plan and then schedule an appointment time that accommodates the patient’s needs.

Patient requests

If a patient requests an accommodation for a disability that is not obvious, providers are permitted to request medical documentation. If the patient’s disability is apparent, additional information should only be requested if necessary.

Practice owners should ensure that staff are trained on assisting patients who request reasonable accommodations based on what the practice is able to provide.