6 January, 2022 17:23

January 6, 2022
The vaccine mandate will be enforced starting 1/27/22.
Dear RHC,

We understand that there is a lot of confusion surrounding the COVID-19 vaccine mandate for RHC facilities. The mandate was first introduced on November 5, 2021, however, CMS did not issue guidance at that time so it was not being enforced at survey.

That has now changed. CMS issued QSO-22-07-ALL and Attachment M on December 28, 2021, which outline the guidance for RHC surveyors. Surveying entities will enforce action starting January 27, 2022.
The following States are still exempt: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Texas, Utah, West Virginia, and Wyoming.
The U.S. Supreme Court will hear oral arguments on the mandate on Friday, January 7, 2022. We await the outcome of the Supreme Court hearing.

If the mandate remains in effect, the following measures must be met:
January 27, 2022 (30 days)

Policies and procedures must be implemented AND 100% of employees must have proof of first dose OR exemption.
February 26, 2022 (60 days)
Policies and procedures must be implemented AND 100% of employees have proof of a completed vaccine series OR exemption.
March 28, 2022 (90 days)

Facilities must maintain compliance with 100% standard or may be subject to enforcement action.
Deficiency Measurements:

Immediate Jeopardy:

  • 40% of staff are unvaccinated OR
  • Under 100% vaccination rate, noncompliant infection control practices by staff AND missing 1 or more required component(s) in policy. PLEASE NOTE: A full list of required policy components can be found on pg. 2-3 of Attachment M.

Condition Level:

  • 21-39% of staff are unvaccinated OR
  • Under 100% vaccination rate AND missing 1 or more required component(s) in policy

Standard Level:

  • Missing 1 (or more) required component(s) in policy OR
  • Under 100% vaccination rate but have good faith effort toward vaccine compliance

We are seeking clarification to determine if exempt employees count as vaccinated in the deficiency measurement calculations above. We will continue to monitor CMS instructions and Supreme Court developments. We will send more information when it is available.
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