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Home Court filings Apter v. Department of Health and Human Services Exhibit 9 (Sentara COVID-19 Treatment Guidelines) — Apter v. HHS

Court filing

Exhibit 9 (Sentara COVID-19 Treatment Guidelines) — Apter v. HHS

Filed June 2, 2022 in Apter v. Department of Health and Human Services; one of 66 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of Texas (Galveston Division)
Filed2022-06-02

U.S. District Court for the Southern District of Texas (Galveston Division) · No. 3:22-cv-00184 · Doc. 1-9 · 2022-06-02 · Docket on CourtListener

Full text

Exhibit 9
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 1 of 9

E-Mail Joel Bundy 10/6/2021
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 2 of 9

 
 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 3 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 1 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
Mechanical Ventilation - Mortality increases after initiation of mechanical vent support; consider decreasing SaO2 target to greater than or equal to 85%.   
Proning 
 
Recommend proning for 16 hours per day while on ventilatory support with P/F ratio <150 (can consider earlier) 
 
Consider setting up proning team at facilities that don’t currently have it 
 
Encourage awake proning for those not on mechanical ventilation 
 
Respiratory/Ventilation 
 
Use static compliance, physiology, and radiographic evidence to guide selection of high peep vs. low peep strategy 
 
Avoid volume overload; do not provide Surviving Sepsis 30 cc/kg IV fluid bolus to avoid worsening oxygenation  
 
If intubation is required, should be performed by most experienced intubator available, with video laryngoscopy 
 
Early discussion of goals of care and potential involvement of palliative medicine is recommended  
 
If unable to wean off ventilator, consider tracheostomy 
 
ENDORSED PHARMACOLOGIC THERAPIES 
DVT Prophylaxis 
All COVID (+) patients should receive enoxaparin as prophylaxis for deep venous thrombosis, unless contraindicated. 
 
Pharmacy may automatically interchange orders for heparin SC to enoxaparin for the COVID population when clinically 
appropriate.   
 
Anticoagulation 
Treatment 
 
COVID-19 positive patients appear to have a process consistent with hypercoagulable disseminated intravascular coagulation 
(DIC).  Society recommendations differ for anticoagulation based on the severity and trajectory of disease.   
 
Enoxaparin is the preferred agent 
 
Consider monitoring anti-Xa levels for patients who are obese, critically ill, or CrCL < 50 (check 4 hours after 3rd dose) 
 
ICU or critically-ill patients: should NOT be empirically anticoagulated based on d-dimer alone 
 
Anticoagulation should be utilized for all clinically indicated disease states, including VTE, atrial fibrillation, and others 
but not based on d-dimer alone in this population 
 
Recommend standard VTE prophylaxis with enoxaparin as the preferred agent – enoxaparin 40mg SC q24h 
 
Non-ICU Patients: MAY benefit from being empirically anticoagulated for 14 days or until discharge based on elevated d-dimer 
of at least 2x the ULN in conjunction with additional risk factors 
 
Weigh risk vs benefit for each patient, especially those on dual antiplatelet therapy or at high risk of bleeding 
 
Enoxaparin is the preferred agent at 1mg/kg SC q12h or 1.5mg/kg SC q24h 
 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 4 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 2 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
Remdesivir 
 
*Course may be 
continued if patient’s 
oxygen status worsens 
but should be held or 
stopped for renal or liver 
dysfunction. 
 
Initiation Use Criteria – Inpatients Only.  Discharge should NOT delayed to complete the 5-day course of Remdesivir. 
 
Lab confirmed diagnosis of COVID-19 
 
Symptom onset within the last 10 days  
 
Oxygen requirements due to COVID: any supplemental nasal cannula or device up to 15 L/min  
(This criteria is derived from patients who saw benefit in the ACTT-1 Trial) 
o Not candidates if on CPAP, BiPAP, high flow device > 15L/min, or mechanical ventilatory support 
o Consider patient’s baseline oxygen requirements when reviewing inclusion/exclusion criteria 
 
CrCl > 30 ml/min 
 
LFTs < 10x ULN 
Systemic Corticosteroids 
Systemic corticosteroids show mortality benefit in patients on mechanical ventilation or oxygen support. Caution is advised 
with previously immunosuppressed patients and/or increased risk of fungal infection.  Increase steroid dose based on response. 
 
Dexamethasone 6mg IV or PO daily x 10 days (Or methylprednisolone 32mg daily or prednisone 40mg daily) 
 
Expert opinion/not supported yet in literature: Consider increasing methylprednisolone up to 80mg IV BID x 10 days as 
needed 
 
Higher dosing of steroids is beneficial in ARDS.  
 
Methylprednisolone 1 mg per kg IV then 0.5 mg per kg every 12 hours for 7 days - consider BMI for dosing. 
 
Follow with a slow taper of oral prednisone as dictated by clinical course.  Optimal duration of taper is unknown. 
 
Patients receiving steroids who did not require oxygen support showed a trend towards patient harm. (RECOVERY trial) 
Tocilizumab (Actemra) 
*EUA Approval for COVID* 
 
Black Box Warning: for a 
risk of serious infections 
that may lead to 
hospitalization or death, 
including tuberculosis (TB), 
bacterial, invasive fungal, 
viral, and other 
opportunistic infections. 
Patients should be progressing despite high-dose steroids before considering tocilizumab.  Trend IL-6 and CRP to ensure 
inflammation is not due to other causes, especially active or suspected infections.  Serious risk of secondary infection 
following receipt of tocilizumab. Many patients may improve on increased steroid doses and not require tocilizumab. 
 
Weight-based dosing x 1 dose 40- 65kg = 400mg; 66 – 90 kg = 600mg; > 90 kg = 800mg 
 
*Medication is limited to pulmonary/critical care and must meet criteria below:                         Exclusions:                                            
 
IL-6 ≥ 2x ULN (> 14 pg/mL)                                                                                                            1. Immunosuppression 
 
CRP > 7.5mg/dL or 75 mg/L                                                                                                           2. ALT/AST > 5x ULN 
 
Hospitalized < 3 days (all patients), and ICU admission < 24 hours (if applicable)              3. Platelets < 50 
 
Rapidly increasing oxygen needs beyond nasal cannula                                                          4. Not accepting all treatments 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 5 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 3 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
THERAPIES THAT ARE NOT SUPPORTED OR ENDORSED 
Ivermectin 
 
Concentrations needed to inhibit SARS-COV-2 would be difficult to achieve in humans and are extremely toxic.  There is no 
available data on outcomes or efficacy in humans from a RCT.  
 
This medication is not recommended until further studies evaluating appropriate dosing regimens are found to be safe and 
effective.  Several organizations, including AMA, ASHP, CDC, FDA and Merck, have issued statements recommending against 
the use of ivermectin for prevention or treatment of COVID-19.   
 
There is a Call for Immediate End to Prescribing, Dispensing, and Use of Ivermectin to Prevent or Treat COVID-19 Outside 
Clinical Trials. 
Ascorbic Acid (Vitamin C) 
Ascorbic acid IV is not endorsed for treatment or prevention of COVID-19 or sepsis/septic shock.   
Bicalutamide (CASODEX) 
Etoposide (TOPOSAR) 
Fluvoxamine (LUVOX) 
Dutasteride (AVODART) 
Finasteride (PROSCAR) 
 
These medications are NOT endorsed for use in COVID-19.  Many do not have published peer-reviewed, RCT available to 
assess both efficacy and safety in COVID-19. 
 
Use is limited to patients enrolled in a clinical trial for treatment of COVID-19. 
There are other medications currently being studied for use in COVID-19 prevention and treatment.  Until published literature is available to evaluate both 
safety and efficacy these medications will not be endorsed or recommended in Sentara’s COVID-19 treatment guidelines.  Literature will be evaluated on a 
continual basis and the guidelines updated as needed to reflect the on-going changes. 
 
 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 6 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 1 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
Mechanical Ventilation - Mortality increases after initiation of mechanical vent support; consider decreasing SaO2 target to greater than or equal to 85%.   
Proning 
 
Recommend proning for 16 hours per day while on ventilatory support with P/F ratio <150 (can consider earlier) 
 
Consider setting up proning team at facilities that don’t currently have it 
 
Encourage awake proning for those not on mechanical ventilation 
 
Respiratory/Ventilation 
 
Use static compliance, physiology, and radiographic evidence to guide selection of high peep vs. low peep strategy 
 
Avoid volume overload; do not provide Surviving Sepsis 30 cc/kg IV fluid bolus to avoid worsening oxygenation  
 
If intubation is required, should be performed by most experienced intubator available, with video laryngoscopy 
 
Early discussion of goals of care and potential involvement of palliative medicine is recommended  
 
If unable to wean off ventilator, consider tracheostomy 
 
ENDORSED PHARMACOLOGIC THERAPIES 
DVT Prophylaxis 
All COVID (+) patients should receive enoxaparin as prophylaxis for deep venous thrombosis, unless contraindicated. 
 
Pharmacy may automatically interchange orders for heparin SC to enoxaparin for the COVID population when clinically 
appropriate.   
 
Anticoagulation 
Treatment 
 
COVID-19 positive patients appear to have a process consistent with hypercoagulable disseminated intravascular coagulation 
(DIC).  Society recommendations differ for anticoagulation based on the severity and trajectory of disease.   
 
Enoxaparin is the preferred agent 
 
Consider monitoring anti-Xa levels for patients who are obese, critically ill, or CrCL < 50 (check 4 hours after 3rd dose) 
 
ICU or critically-ill patients: should NOT be empirically anticoagulated based on d-dimer alone 
 
Anticoagulation should be utilized for all clinically indicated disease states, including VTE, atrial fibrillation, and others 
but not based on d-dimer alone in this population 
 
Recommend standard VTE prophylaxis with enoxaparin as the preferred agent – enoxaparin 40mg SC q24h 
 
Non-ICU Patients: MAY benefit from being empirically anticoagulated for 14 days or until discharge based on elevated d-dimer 
of at least 2x the ULN in conjunction with additional risk factors 
 
Weigh risk vs benefit for each patient, especially those on dual antiplatelet therapy or at high risk of bleeding 
 
Enoxaparin is the preferred agent at 1mg/kg SC q12h or 1.5mg/kg SC q24h 
 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 7 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 2 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
Remdesivir 
 
*Course may be 
continued if patient’s 
oxygen status worsens 
but should be held or 
stopped for renal or liver 
dysfunction. 
 
Initiation Use Criteria – Inpatients Only.  Discharge should NOT delayed to complete the 5-day course of Remdesivir. 
 
Lab confirmed diagnosis of COVID-19 
 
Symptom onset within the last 10 days  
 
Oxygen requirements due to COVID: any supplemental nasal cannula or device up to 15 L/min  
(This criteria is derived from patients who saw benefit in the ACTT-1 Trial) 
o Not candidates if on CPAP, BiPAP, high flow device > 15L/min, or mechanical ventilatory support 
o Consider patient’s baseline oxygen requirements when reviewing inclusion/exclusion criteria 
 
CrCl > 30 ml/min 
 
LFTs < 10x ULN 
Systemic Corticosteroids 
Systemic corticosteroids show mortality benefit in patients on mechanical ventilation or oxygen support. Caution is advised 
with previously immunosuppressed patients and/or increased risk of fungal infection.  Increase steroid dose based on response. 
 
Dexamethasone 6mg IV or PO daily x 10 days (Or methylprednisolone 32mg daily or prednisone 40mg daily) 
 
Expert opinion/not supported yet in literature: Consider increasing methylprednisolone up to 80mg IV BID x 10 days as 
needed 
 
Higher dosing of steroids is beneficial in ARDS.  
 
Methylprednisolone 1 mg per kg IV then 0.5 mg per kg every 12 hours for 7 days - consider BMI for dosing. 
 
Follow with a slow taper of oral prednisone as dictated by clinical course.  Optimal duration of taper is unknown. 
 
Patients receiving steroids who did not require oxygen support showed a trend towards patient harm. (RECOVERY trial) 
Tocilizumab (Actemra) 
*EUA Approval for COVID* 
 
Black Box Warning: for a 
risk of serious infections 
that may lead to 
hospitalization or death, 
including tuberculosis (TB), 
bacterial, invasive fungal, 
viral, and other 
opportunistic infections. 
Patients should be progressing despite high-dose steroids before considering tocilizumab.  Trend IL-6 and CRP to ensure 
inflammation is not due to other causes, especially active or suspected infections.  Serious risk of secondary infection 
following receipt of tocilizumab. Many patients may improve on increased steroid doses and not require tocilizumab. 
 
Weight-based dosing x 1 dose 40- 65kg = 400mg; 66 – 90 kg = 600mg; > 90 kg = 800mg 
 
*Medication is limited to pulmonary/critical care and must meet criteria below:                         Exclusions:                                            
 
IL-6 ≥ 2x ULN (> 14 pg/mL)                                                                                                            1. Immunosuppression 
 
CRP > 7.5mg/dL or 75 mg/L                                                                                                           2. ALT/AST > 5x ULN 
 
Hospitalized < 3 days (all patients), and ICU admission < 24 hours (if applicable)              3. Platelets < 50 
 
Rapidly increasing oxygen needs beyond nasal cannula                                                          4. Not accepting all treatments 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 8 of 9

Sentara Comprehensive COVID-19 treatment guidelines – VERSION 26 
Endorsed by COVID taskforce, Pharmacy, CC, HM, and ID 
 
This document will be updated as public health priorities and clinical evidence evolve.  Please refer to  
 
P a g e  | 3 
the Sentara COVID-19 website or MD Office for the most up to date information.  This documented is intended  
 
        Updated: 9/27/2021 
to help clarify decision points and allow clinicians to gain a better understanding of system endorsed recommendations. 
 
 
 
 
THERAPIES THAT ARE NOT SUPPORTED OR ENDORSED 
Ivermectin 
 
Concentrations needed to inhibit SARS-COV-2 would be difficult to achieve in humans and are extremely toxic.  There is no 
available data on outcomes or efficacy in humans from a RCT.  
 
This medication is not recommended until further studies evaluating appropriate dosing regimens are found to be safe and 
effective.  Several organizations, including AMA, ASHP, CDC, FDA and Merck, have issued statements recommending against 
the use of ivermectin for prevention or treatment of COVID-19.   
 
There is a Call for Immediate End to Prescribing, Dispensing, and Use of Ivermectin to Prevent or Treat COVID-19 Outside 
Clinical Trials. 
Ascorbic Acid (Vitamin C) 
Ascorbic acid IV is not endorsed for treatment or prevention of COVID-19 or sepsis/septic shock.   
Bicalutamide (CASODEX) 
Etoposide (TOPOSAR) 
Fluvoxamine (LUVOX) 
Dutasteride (AVODART) 
Finasteride (PROSCAR) 
 
These medications are NOT endorsed for use in COVID-19.  Many do not have published peer-reviewed, RCT available to 
assess both efficacy and safety in COVID-19. 
 
Use is limited to patients enrolled in a clinical trial for treatment of COVID-19. 
There are other medications currently being studied for use in COVID-19 prevention and treatment.  Until published literature is available to evaluate both 
safety and efficacy these medications will not be endorsed or recommended in Sentara’s COVID-19 treatment guidelines.  Literature will be evaluated on a 
continual basis and the guidelines updated as needed to reflect the on-going changes. 
 
 
Case 3:22-cv-00184   Document 1-9   Filed on 06/02/22 in TXSD   Page 9 of 9

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