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AHCA/NCAL: New Template Policies and Procedures Available on CMS Staff Vaccine Mandate

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.

AHCA/NCAL will host a webinar on how to implement religious and medical exemptions to the mandate on November 22 at 4 PM Eastern, so mark your calendars and stay tuned for login information.

CMS’s Staff Vaccine Mandate: Implementing Religious & Medical Exemptions 

Presented by Craig S. Roberts and Henry S. Shapiro, labor and employment attorneys with Jackson Lewis, P.C.

Monday, November 22, 2021
4:00 PM Eastern
Watch for login information next week.

Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

NYSHFA/NYSCAL CONTACTS:

Jackie Pappalardi, RN, BSN
Executive Director
518-462-4800 x16

Lisa Volk, RN, B.P.S., LNHA
Director, Clinical & Quality Services
518-462-4800 x15