CMS Vaccine Update


CMS Vaccine Update

by | CMS and Mandates, News

TruNovus recently learned about an update to the CMS (Center for Medicare & Medicaid Services) Vaccination Rule and how it applies to behavioral health facilities. We encourage you to review this information for your benefit and understanding.

As of November 4, the Biden Administration is requiring COVID-19 vaccination of eligible staff at health care facilities that participate in the Medicare and Medicaid programs. Under this list of facilities required to follow this rule includes “Psychiatric Residential Treatment Facilities” or behavioral health and mental health facilities.

If you are a facility that accepts Medicare & Medicaid insurance, please review the following information:

Under CMS rules you must:

BY December 6, 2021

  • Implement policies and procedures to vaccinate covered staff.
    • Staff includes all employee’s, volunteers and contractors.
  • Covered staff, as defined above, must receive the J&J Vaccine or the first dose of Pfizer or Moderna before they provide any care by, treatment or other services for the facility or it’s patients unless exempted, or persons vaccinated is delayed due to contraindications.

By January 4, 2022

  • Covered staff must be fully vaccinated unless exempted or persons vaccinated is delayed due to contraindications.
    • Fully vaccinated generally means receiving final dose + 14 days.
    • For purposes of January 4, 2022 deadline, staff who have received the final dose are deemed to be fully vaccinated without the 14 days.

Boosters are not currently required to be fully vaccinated.

If you do not accept Medicare & Medicaid insurance currently, but plan to in future, please make yourself and executive team aware of this rule that will apply to your facility once insurance is accepted.

As of November 29, a federal judge blocked the CMS rule and vaccine requirement in Missouri, Nebraska, Arkansas, Kansas, Iowa, Wyoming, Alaska, South Dakota, North Dakota and New Hampshire.

How TruNovus helps our clients during the pandemic:

Offer support creating and/or adapting policies and procedures, including a checklist of what your policies and procedures need to include.

  • Process to ensure covered staff are fully vaccinated (unless exempted)
  • Process for staff to request exemption based on federal law (Title VII and ADA)
    • Disability or medical condition + required documentation
    • Sincerely held religious belief
  • Additional precautions to mitigate spread of COVID-19 for staff who are not fully vaccinated.

Support tracking and documenting:

  • Vaccination status of covered staff
  • Vaccination status of booster doses
  • Vaccination status of those whose vaccination was delayed due to contraindications recognized by the CDC
  • Information from those who have been granted exemption

Create contingency plans for staff who are not fully vaccinated.

For example:

  • What if there is another outbreak?
  • How do you provide care in the case that employees get sick?
  • How do we keep patients safe?

If you need help revising handbook policies, getting updates on Behavioral Health legislature or supporting your company culture in the midst of mandates, please reach out to chat!

To learn more about the CMS vaccine update, please read this article published by Kim Stranger at Holland and Heart

Photo Credit: Alex Wong, Getty Images


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