The regulation requires that these facilities establish a policy ensuring all eligible staff have received the first dose of a two-dose or one-dose COVID-19 vaccine by December 5, 2021, with all eligible staff being fully vaccinated by January 4, 2022. The regulation provides for exemptions based on recognized medical conditions or religious beliefs, observances, or practices, which must be included in the facilities’ policy. CMS has indicated that it will ensure compliance with these requirements through established surveys and enforcement processes.
Every facility under this regulation should prepare and implement policies to ensure all eligible staff are vaccinated within the allotted time frames, taking into account exemptions, as required. Facilities that fail to implement appropriate policies could face enforcement processes by CMS. Please contact Meghan Riordan or Matt Utecht with HSB’s Healthcare Practice should you have questions about this regulation.