If you jack up th car really high on the side you are working on you can do it without too much mess at all. Try wrapping aluminum foil all over the exhaust to keep the oil off of them.
i haven't adjusted valves without draining the oil but i replaced a valve cover gasket with oil in ther engine and only lost a few ounces.
Like root says, oil will gradually flow from the tank to the engine sump over time and can make a mess.
I once pulled a return tube off with the car jacked up on that side. It dripped for a few minutes and then stopped. I watched it for about 10 minutes and decided it was cool.
The next morning I had several quarts on the floor. bad deal. At least my concrete will never rust