Vaccine Mandate Rules Published
The Centers for Medicare and Medicaid Services (CMS) issued an emergency regulation last week requiring COVID-19 vaccines for health care workers. The Occupational Safety and Health Administration (OSHA) has also issued emergency guidance for federal workers, federal contractors, and anyone employed by a company with 100 or more employees.
Resources are available to help health centers comply with the CMS rule:
Importantly, the interim final rule requires that community health centers have a detailed set of policies and procedures relating to the federal vaccine mandate in place by December 6, 2021. Details of what must be addressed in the policies and procedures are laid out in the new regulatory language for health centers. Health center boards should approve of the policies. The rule also clarified that the mandate does not apply to CHC employees or contractors who exclusively provide telehealth or other services from outside of any CHC sites and never have direct contact with patients or other staff. The rule does apply, however, to volunteers including board members who set foot inside any health center site.
Upcoming deadlines:
- By, December 6, 2021:
- All staff must have:
- received their first dose of the Pfizer or Moderna vaccine OR
- received their only dose of the J&J vaccine OR
- a temporary delay for medical reasons OR
- requested a medical or religious exemption.
- Community health centers must have developed and implemented appropriate policies and procedures to comply with the vaccine mandate.
- By January 4, 2022:
- All staff who got the Pfizer or Moderna vaccine must receive their second dose.
- All unvaccinated staff must either:
- have received approval for a medical or religious exemption, and be receiving accommodations that OR
- have a CDC-supported reason for temporarily delaying getting a COVID vaccine.
- Health centers must have implemented additional precautions to minimize the risk of transmission of COVID for accommodated individuals.
On 12:00 PM on Thursday, November 11, the National Association of Community Health Centers (NACHC) and Feldesman Tucker Leifer Fidell (FTLF) will be jointly hosting a webinar reviewing the vaccine mandate. Click here to register. If you cannot attend the event “live”, you can register to receive access to the recording directly from FTLF. |