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CMS Vaccine Mandate and Implementing Additional Precautions for Unvaccinated Staff

Posted Feb 22, 20222 min Read

Regulatory & Clinical

The Centers for Medicare and Medicaid Services (CMS) staff vaccination rule requires facilities to take additional precautions for those staff who remain unvaccinated due to a medical/religious exemption or newly hired staff who only have the first dose of the two-dose series. CMS provides a list of additional possible actions, job modifications a facility can implement as additional precautions in QSO memos QSO-22-07-LTC, QSO-22-09-LTC, and QSO-22-11-LTC.

Facilities are not required to follow all the possible actions listed by CMS in the QSO memos but are encouraged be intentional and to take a layered approach based on risk of transmission of COVID-19 to the residents served in the nursing home.

CMS provided a list of actions a facility may choose to implement as additional precautions for staff members, which includes, but is not limited to:

  • Reassigning of staff to non-patient care areas, remote work, or duties that limit exposure to those most at risk (e.g., immunocompromised, or unvaccinated).
  • Test unvaccinated staff at a higher frequency than required by CMS requirements or CDC guidance. This guidance hinges on community transmission.
  • Following additional CDC recommended precautions, such as universal source control and physical distancing measures.
  • Requiring staff to use NIOSH-approved N95 or equivalent or higher-level respirator for designated duties or the entire time inside the facility.


  • Establish policies and procedures around additional precautions for unvaccinated staff.
  • Review current CDC, CMS and state guidelines and requirements and know the difference of what is required and what is more restrictive and additional precautions for unvaccinated staff.
  • Establish education for all employees related to policies and procedures and expectations related to additional precautions and requirements.
  • Establish ongoing surveillance and oversight to ensure compliance shift to shift.
  • Unvaccinated staff will be interviewed during the survey process and observed and will be a risk area for nursing homes.

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About the Author

Lori Davenport, Director of Clinical & Regulatory Affairs