Preparing for Phase 1 of the CMS Vax Mandate: December 5, 2021 is Fast Upon Us
On November 8, 2021, the Centers for Medicare and Medicaid Services (CMS) published its long-anticipated Interim Final Rule with Comment (IFC) that requires covered facilities to mandate that all staff be fully vaccinated by January 4, 2021 subject to very limited exceptions. There is no testing opt-out. The IFC is divided into two phases, and CMS has indicated that surveyors will be looking for compliance during recertification and complaint surveys. Providers who are not in compliance will be subject to as yet unspecified enforcement actions. What will surveyors be looking for?
PHASE 1 Compliance Deadline is December 5, 2021:
- Have all staff received, at a minimum, the first dose of the primary series or a single dose COVID-19 vaccine, or requested and/or been granted a lawful exemption prior to staff providing any care, treatment, or other services for the facility and/or its patients?
- Do you have a process and plan for vaccinating all eligible staff?
- How are you handling exemptions and accommodations?
- Are you tracking and documenting staff vaccinations ?
PHASE 2 Compliance Deadline is January 4, 2022:
- Have all staff completed their primary vaccination series, except for those staff have been granted exemptions, or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by CDC, due to clinical precautions and considerations?
Join Paula Sanders and the PHCA staff for an interactive discussion about what you should be doing now to meet these deadlines and steps to consider as you implement the CMS Vax Mandate.
1 CEU for SNF, AL, PC, Human Resources
Click here to register
