On December 29, 2021, the Centers for Medicare and Medicaid Services (CMS) released the “Guidance for the Interim Final Rule – Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccinations.” The interim final rule was published on November 5, 2021.
This guidance provides important information on implementation and enforcement, as well as guidelines to assess and maintain compliance with the COVID-19 vaccination requirements for healthcare workers at facilities participating in the Medicare and Medicaid programs, which include:
- Long Term Care and Skilled Nursing Facilities (nursing homes)
- Ambulatory Surgery Centers
- Psychiatric Residential Treatment Facilities
- Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs/IID)
- Home Health Agencies
- Comprehensive Outpatient Rehabilitation Facilities
- Critical Access Hospitals
- Outpatient Physical Therapy
- Community Mental Health Centers
- Home Infusion Therapy
- Rural Health Clinics/Federally Qualified Health Centers
- End Stage Renal Dialysis Facilities
The overall and provider-specific guidance can be found here.
Buchanan’s labor & employment and healthcare attorneys are available to help companies navigate the new CMS guidance to ensure compliance as well as help counsel on related workforce implications.