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New Template Policies and Procedures Available on CMS Staff Vaccine Mandate

Posted Nov 12, 20212 min Read

Regulatory & Clinical

Last week, the Centers for Medicare and Medicaid Services (CMS) published an Interim Final Rule (IFR) requiring Skilled Nursing Facilities, Nursing Facilities, and ICF-IIDs to establish a policy ensuring that all eligible staff be vaccinated for COVID-19 or request a medical or religious exemption.

The implementation dates for this rule are as follows:

  • Phase 1 – December 6, 2021: Staff must have received at least the first dose of a two-dose COVID-19 vaccine or a one-dose COVID-19 vaccine.
  • Phase 2 – January 4, 2022: Staff must be fully vaccinated, except staff who have been granted exemptions, or those whom COVID-19 vaccination must be temporarily delayed as recommended by the CDC due to clinical precautions and considerations.

It’s important that providers put a policies and procedures in place NOW to come into compliance with these requirements. To assist members, AHCA/NCAL has developed a template policies and procedures (P&P) that members can personalize to meet their needs. Note that this P&P document will be updated once CMS has released its interpretive guidance.