CMS Revises HCP COVID Vaccination Guidance

CMS has revised guidance for healthcare facility staff COVID-19 vaccination requirements to address the frequency of review of the facility staff vaccination requirement compliance policies. CMS emphasizes that, per the Omnibus COVID-19 Health Care Staff Vaccination interim final rule, implemented November 5, 2021, facility staff vaccination rates under 100 percent constitute noncompliance (although facilities must have a process by which staff may request medical or non-medical exemptions based on applicable federal law). Revised guidance indicates that surveyors will only be expected to perform compliance reviews of staff vaccination requirements as part of initial certification, standard recertification or reaccreditation surveys, and in response to specific complaint allegations related to the staff vaccination requirements. The revised CMS guidance document (QSO-23-02-ALL) includes attachments A – N providing facility-specific guidance.

Please note that the CMS definition of “fully vaccinated” in this rule (two weeks or more from completion of primary COVID-19 vaccination series) is different than the CDC definition of “up to date” (completion of COVID-19 vaccine primary series plus receipt of the most recent booster dose recommended by CDC for your situation).