CMS Mandatory COVID-19 Vaccination Rule: What Does the Future Hold?

The CMS Omnibus COVID-19 interim final rule with comment (IFC) requires certain providers and suppliers to implement a COVID-19 vaccine policy and ensure their staff is fully vaccinated as a Condition of Participation/Condition for Coverage in Medicare. COVID-19 testing is not an option under the IFC, and there are significant sanctions for failure to comply.

While the basics of the rule may be clear, the IFC's application to individuals and vendors under contract with healthcare facilities has raised significant questions regarding the scope of the rule and implementing an effective vaccine policy.

Please join us as we discuss the implementation of the IFC and the many gray areas healthcare entities are facing.

TOPICS WILL INCLUDE:

• Determining scope of coverage and legal exemptions
• Establishing policies and processes to ensure compliance
• Meeting the deadlines for each phase (December 5, 2021, and January 4, 2022)
• Navigating arrangements with contractors and vendors
• Evaluating the IFC's interaction with OSHA
• ETS requirements