Some individuals may use a medical exemption request as a pretext for obtaining an exemption for non-medical reasons. The Biden administration is considering a Republican proposal to strike the COVID-19 vaccine mandate for the U.S. military, a development that signals future possibility of reversal of the same . . While a less-dire public health situation could, in theory, pull a more conservative justice over to the other side, the court will not revisit the same case anytime soon unless the facts significantly change, Hodge said. Businesses opting for their own mandates can take steps to minimize claims and exposure. Plans and issuers must cover COVID-19 vaccines without cost sharing even when provided by out-of-network providers and must reimburse out-of-network providers a reasonable amount for vaccine administration; federal regulations specify the Medicare reimbursement rate for vaccine administration is a reasonable amount. or On April 1 of this year, after the prohibition expires, states will resume removing people who no longer qualify or do not furnish needed information. Monday - Friday 7am - 5pm (EST). All Rights Reserved. Phase 2 focuses on getting all staff members vaccinated with their second or final vaccine dose (e.g.,for single shot vaccines), while accommodating/granting protectedexemptions and delays due to medical issues. Like healthcare worker vaccination mandates, employer vaccination mandates have been promulgated at both the federal and state levels. Possible Enforcement Mechanisms CMS has noted that it has a variety of enforcement mechanisms available from issuance of civil monetary penalties and denial of payments for new admissions to . The CMS Vaccination Mandate was the target of immediate legal challenges, which culminated with the U.S. Supreme Court on January 13, 2022 ruling inBiden v. Missourithat the mandate was a valid exercise of CMS regulatory authority to revise the conditions of participation, conditions for coverage, and requirements for participation in the Medicare and Medicaid programs. The Centers for Medicare & Medicaid Services maintains a more complete list of coronavirus waivers and flexibilities that have been exercised since early 2020; some state actions to respond to. FDA grants full approval to Pfizer's COVID-19 vaccine for 12-15 age group. In contrast to its holding in the companioncase regarding the CMS Vaccination Mandate, the Court concluded inNational Federation of Independent Business (NFIB) v. Department of Laborthat OSHA lacked authority to impose the mandate in the General ETS. means youve safely connected to the .gov website. 2022-04-05 Summary Memorandum Summary Effective 10-26-22, this memo has been superseded by QSO-23-02-ALL, Revised Guidance for Staff Vaccination Requirements. You can decide how often to receive updates. To be compliant, 100% of a facilitys staff must have completed their primary vaccine series for both single and multiple dose vaccines by February 28, 2022. Idahos Medicaid program had nearly 450,000 enrollees as of February. Had the Healthcare ETS continued in effect, it would have impacted many physician practices, given that it applied broadly to all settings where any employee provided healthcare services or healthcare support services.But, on December 27, 2021, OSHA withdrew the Healthcare ETS. The early days of the COVID-19 pandemic were marked by several emergency declarations made by the federal government, under several broad authorities, each of which has different requirements related to expiration. . https:// For example, the CMS Vaccination Mandate includes a medical exemption for individuals who obtain documentation confirming recognized clinical contraindications to COVID-19 vaccines that is signed by a licensed practitioner, such as a physician, who is not the individual requesting the exemption, and who is acting within their respective scope of practice as defined by, and in accordance with, all applicable State and local laws.Similar medical exemptions are common in state-imposed healthcare worker vaccination mandates. KHN is an editorially independent program of KFF (Kaiser Family Foundation). It is at least possible that OSHA could pursue a, In some states, moreover, physicians may have to contend with, For example, the CMS Vaccination Mandate includes a medical exemption for individuals who obtain documentation confirming recognized clinical contraindications to COVID-19 vaccines that is signed by a licensed practitioner, such as a physician, who is not the individual requesting the exemption, and who is acting within their respective scope of practice as defined by, and in accordance with, all applicable State and local laws.. Log in to access all of your BLAW products. or Evaluating Compulsory Covid-19 Vaccination Mandates: Defining 'Referral' in the Anti-Kickback Statute, American Bar Association For the first two years of the pandemic, when Idaho received returned mail with an out-of-state forwarding address or no forwarding address possibly indicating the enrollee no longer lived in Idaho Leach said state officials would call them. , Thank you for your interest in supporting Kaiser Health News (KHN), the nations leading nonprofit newsroom focused on health and health policy. A lot of the calls went unanswered, he said. Still, theres just a lot of variation in terms of what that could look like, said Farah Erzouki, a senior health policy analyst for theCenter on Budget and Policy Priorities, a think tank in Washington, D.C. Are you sure you want to log out of your account? "At this point in the pandemic, the case for vaccine mandates is much weaker than it was in 2021," she adds. 7500 Security Boulevard, Baltimore, MD 21244, An official website of the United States government, emergency use authorizations (EUAs) of the updated (bivalent). The Centers for Medicare & Medicaid Services today released a memorandum and provider-specific guidance on complying with its interim final rulerequiring COVID-19 vaccinations for workers in most health care settings, including hospitals and health systems, that participate in the Medicare and Medicaid programs. Recent guidance by the Medical Board of California offers a cautionary reminder: [A] physician who grants a mask or other exemption without conducting an appropriate prior exam and without a finding of a legitimate medical reason supporting such an exemption within the standard of care may be subjecting their license to disciplinary action.. The inability to reach Medicaid enrollees has been a long-standing problem. Even as case numbers drop, Covid-19 transmission will continue to be a patient safety risk for quite a long while to come and vulnerable patients and nursing home residents will still need the protection that the vaccination requirement provides, said Lindsay Wiley, professor of law at UCLA School of Law. Your patients may know these as "updated COVID-19 vaccines": Pfizer-BioNTech: all patients 6 months - 4 years old. In meetings with CMS, Idaho officials were told the state could not kick people off if it didnt make physical contact, Shane Leach, administrator of the Division of Welfare at Idahos Department of Health and Welfare, recounted in correspondence with CMS. The interim final rule takes effect immediately. Senate Republicans recently voted to block the mandate, but the victory was more symbolic than anything else and wont gain traction in the House or at the White House, said Sarah Coyne, a partner at Quarles & Brady LLP. CMS is committed to working with states to ensure continuity of coverage for eligible individuals, including those for whom the Medicaid agency receives returned mail, Bruce Alexander, director of CMS office of communications, said in a written statement to KHN. The FDA amended EUAs to authorize the use of first booster doses, as follows: On August 23, 2021, the FDA approved the Pfizer-BioNTech COVID-19 vaccine, marketed as COMIRNATY, for the prevention of COVID-19 disease in patients 16 years and older. People get the fourth shot late in 2022 so it drops off after day 100. . As further evidence that the vaccine-or-test mandate falls within OSHA's purview, the dissent highlighted that, last year, Congress appropriated $100 million for OSHA "to carry out COVID-19. it's easy: simply make the Medicare death-vaccination record-level data publicly . Legal victories have been few and far between for Bidens vaccine mandates, said James Hodge, director of the Center for Public Health Law and Policy at Arizona State University. Published: Jan 31, 2023. Among the major changes to Medicare coverage of telehealth during the PHE: Federally qualified health centers and rural health clinics can provide telehealth services to Medicare beneficiaries (i.e., can be distant site providers), rather than limited to being an originating site provider for telehealth (i.e., where the beneficiary is located), All 50 states and DC expanded coverage and/or access to telehealth services in Medicaid. Termination is the last resort after the provider has been given sufficient opportunities to reach full compliance. Depending on its particulars, a state anti-mandate could create a conflict which might be resolved only through litigation with the requirements of the CMS Vaccination Mandate and future rulemaking by federal OSHA. . Similarly, the Healthcare ETS included an exception to its requirement that employers remove employees from the workplace in instances of close contact exposure for asymptomatic employees who are vaccinated. A federal government website managed and paid for by the U.S. Centers for Medicare & Medicaid Services. To request permission to reproduce AHA content, please click here. Similarly, the Healthcare ETS included an exception to its requirement that employers remove employees from the workplace in instances of close contact exposure for asymptomatic employees who are vaccinated. 2023 Kaiser Family Foundation. No later than six months after 319 PHE ends, Other Medicare Payment and Coverage Flexibilities. COVID-19 vaccination mandates comprise a patchwork of continually developing federal, state, and private-sector requirements, some of which have prompted lawsuits, including the recent Supreme Court cases, challenging the validity of such mandates. In addition to COVID-19 vaccination mandates for healthcare workers, another iteration of vaccination mandates may apply to physicians: COVID-19 vaccination requirements applicable to employers. . For example, the Healthcare ETS created an exception to its requirements for personal protective equipment (PPE), physical distancing, and physical barriers for vaccinated employees in well-defined areas where there is no reasonable expectation that any person with suspected or confirmed COVID-19 will be present . The Biden administration is changing its messaging as the omicron surge subsides, and many people are eager to take a break from prevention strategies like masking and staying home. It is at least possible that OSHA could pursue amore stringentapproach and adopt a COVID-19 vaccination mandate in the healthcare sector, potentially reaching those healthcare employers not subject to the CMS Vaccination Mandate a possibility theNFIBdecision leaves open. On June 17, 2022, the FDA authorized emergency use of the Moderna and Pfizer-BioNTech vaccines for the prevention of COVID-19 to include use in children as young as 6 months: On May 17, 2022, the FDA amended the Pfizer-BioNTech COVID-19 vaccine (PDF) EUA to authorize the use of a single booster pediatric dose (orange cap) for all patients 5-11 years old. The U. S. Supreme Court on Oct. 3 declined a case brought by 10 states challenging the Biden administration's rule that requires employees to be vaccinated against COVID-19 if they work in . For its part, OSHAs General ETS included an exemption to be included in an employers mandatory vaccination policy for employees [f]or whom a vaccine is medically contraindicated.Even many state employer vaccinationanti-mandatesinclude a medical exemption component, insofar as theyrestrictan employer from mandating COVID-19 vaccination for employees who qualify for a medical exemption. Heres how you know. Of those, CMS estimated that 2.4 million were unvaccinated when it issued the IFR.
To this end, the Healthcare ETS enumerated various measures that applicable employers had to implement to reduce transmission of COVID-19 in healthcare workplaces, including support for COVID19 vaccination for employees through reasonable time off and paid leave protections. A federal government website managed and paid for by the U.S. Centers for Medicare & Medicaid Services. While the memorandum specifically applies to Texas, the guidance and rule apply to all states. People may not realize theyve been dropped until they seek care. Employees who have not begun the vaccination process and do nothave an approved exemption or an exemption pending,have beenplacedon anunpaid leaveof absence (LOA)beginning today. Apr 06, 2022 - 03:59 PM The Centers for Medicare & Medicaid Services today released a memorandum and provider-specific guidance on complying with its interim final rule requiring COVID-19 vaccinations for workers in most health care settings, including hospitals and health systems, that participate in the Medicare and Medicaid programs. A covid relief law Congress enacted in 2020 prohibited states from removing people from Medicaid except in a few narrow circumstances, such as if an enrollee died or moved out of state. The Biden administration should have never imposed this mandate, and CMS should now throw it in the trash bin where it belongs." The IFR regulates over 10 million healthcare workers and suppliers in the United States. It is rare that the public health criteria change so rapidly, but welcome to Covid-19.. Secure .gov websites use HTTPSA rpradhan@kff.org, Ayesha Mehdi is a partner at Spencer Fane, LLP's Las Vegas office. As a result of the Courts decision, most Medicare- and Medicaid-certified providers and suppliers must now proceed to develop and implement policies and procedures under which all staff are vaccinated for COVID19. . @rachanadixit, By Rachana Pradhan Up-to-date phone numbers or email addressesmay not be availableto state and county workers. Physicians should also be cognizant of privacy-related considerations in disclosing an individuals health information to an employer or other third party. Ultimately, however, employers were spared from having to make the vaccination-or-testing choice because the U.S. Supreme Court stayed enforcement of the General ETS on January 13, 2022. It remains to be seen if any future healthcare-focused regulation from OSHA will take the same form as the Healthcare ETS. Besides, the current public health emergency wasnt a key element of the Supreme Courts reasoning when it allowed the vaccine mandate to resume. Alternatively, OSHA permitted an employer to accept proof of regular COVID-19 testing from unvaccinated employees who would have to wear a face covering meeting specified requirements. This pre-diluted vaccine is effective January 3, 2021. ( Second, physicians should familiarize themselves with the compliance obligations associated with granting or denying a medical exemption. Editors Note: This brief was updated on Jan. 31, 2023 to clarify implications related to the end of the national emergency and public health emergency on May 11, 2023. COVID-19: CDC, FDA and CMS Guidance. Finally, COVID-19 vaccination mandates may apply to physicians in an indirect, yet still significant, manner: as the gatekeepers charged with determining whether other individuals qualify for a medical exemption to an otherwise applicable vaccination mandate. On August 19, 2022, the FDA amended the Novavax COVID-19 vaccine, AdjuvantedEUA to authorize the use for all patients 1217 years old. March 21, 2022, 2:35 AM. It shows how easily state bureaucracies can disenroll people they shouldnt be disenrolling, leaving those people in financial and medical jeopardy. How Much Could COVID-19 Vaccines Cost the U.S. After Commercialization? The damage will be done, saidTricia Brooks, a research professor with Georgetown Universitys Center for Children and Families. Follow @jcubanski on Twitter Hospitals can be generous in offering religious and medical exemptions, but need to otherwise have a 100% vaccination rate to be compliant. CMS Enforcement Penalties for Non-Compliance. But if CMS had issued a written version of the standard to which it was holding Idaho in which disenrollments would be justified only if the state made contact with the enrollee Medicaid consumer advocates and other specialists said they were unaware of it. HHS issued, Health care providers about your signed agreements to administer COVID-19 vaccines to patients free-of-charge, Group health plans and health insurers that youre legally required to cover COVID-19 vaccines and diagnostic testing without patient cost sharing, Administer the vaccine with no out-of-pocket cost to your patients for the vaccine or administration of the vaccine, Vaccinate everyone, including the uninsured, regardless of coverage or network status, Providers who have questions about billing or reimbursement of vaccine administration for patients covered by private insurance or Medicaid should contact the respective health plan or, Providers administering the vaccine to people without health insurancewere able to request reimbursement for the administration of the COVID-19 vaccine through the, Providers administering the vaccine to underinsured individuals were able to request reimbursement for the administration of the COVID-19 vaccine through the, How you can enroll in Medicare to bill for administering COVID-19 vaccines, The COVID-19 vaccine Medicare coding structure, Medicare payment rates for administering COVID-19 vaccines, How tobillcorrectly for administering vaccines, including roster and centralized billing, Monoclonal antibody infusion for treating COVID-19, New COVID-19 Treatments Add-on Payment (NCTAP), Enrollment for Administering COVID-19 Vaccine Shots, Medicare Billing for COVID-19 Vaccine Shot Administration, SNF: Enforcement Discretion Relating to Certain Pharmacy Billing, Beneficiary Incentives for COVID-19 Vaccine Shots, CMS Quality Reporting for COVID-19 Vaccine Shots, New COVID-19 Treatments Add-On Payment (NCTAP), FDA limited the authorized use of the Janssen COVID-19 vaccine, Janssen COVID-19 vaccine (Johnson & Johnson), COVID-19 vaccine guidance for moderately or severely immunocompromised patients, Health Resources & Services Administration (HRSA)COVID-19 Uninsured Program, Patients 18 years and older for whom other authorized or approved COVID-19 vaccines are not accessible or clinically appropriate, Patients 18 years and older who elect to receive the Janssen COVID-19 vaccine because they would otherwise not receive a COVID-19 vaccine, Third primary series dose in certain immunocompromised patients 18 years and older, Single booster dose for patients 18 years and older, 2-dose primary series for patients 5 years and older, Third primary series dose in certain immunocompromised patients 5 years and older, Single booster dose for patients 12 years and older, Charge your patients for an office visit or other fee if COVID-19 vaccination is the only medical service given, Require additional medical or other services during the visit as a condition for getting a COVID-19 vaccination, They only have Medicare Part A but not Part B coverage (or supplemental coverage for Part B services, like vaccine administration), Their insurance doesnt include the COVID-19 vaccine administration fees as a covered benefit (like Medicare Part A only), Their health insurance covers the COVID-19 vaccine administration but with cost sharing. Subscribe to KHN's free Morning Briefing. COVID-19 vaccination mandates comprise a patchwork of continually developing federal, state, and private-sector requirements, some of which have prompted lawsuits, including the recent Supreme Court cases, challenging the validity of such mandates. website belongs to an official government organization in the United States. In prior court opinions that ruled against the mandates, some of the judges reasoning was that the pandemic is not really an emergency, said Seema Mohapatra, visiting professor of law at SMU Dedman School of Law. Those who do not receive their vaccinations and who do not have an approved exemption will be placed on an unpaid leave of absence. . This toolkit includes information to describe: Sign up to get the latest information about your choice of CMS topics. .gov Idaho Gov. The CMS COVID-19 vaccination mandate, available at: CMS Final Rule: Vaccine Mandate, requires certain employers who are certified under the Medicare and Medicaid programs to issue a policy requiring all employees to be vaccinated against COVID-19 within 60 days of the publication of the regulation in the Federal Register, which occurred on . But that is not the case for a lot of situations.. Similar medical exemptions are common in state-imposed healthcare worker vaccination mandates. Surveyors in these states should not undertake any efforts to implement or enforce the IFC. On Jan. 13, 2022, the U.S. Supreme Court ruled that the COVID-19 vaccine mandate issued by the Centers for Medicaid and Medicare (CMS) is allowed to move forward for healthcare workers in the U.S. Americans can getvaccines purchased with U.S. taxpayer dollarsat no cost. Jul 8, 2022. Physicians should continue to monitor these regulatory developments and assess their impact from an employer standpoint. Americans can getvaccines purchased with U.S. taxpayer dollarsat no cost. Jennifer Tolbert , The vaccine remains available under EUA, including: The FDA authorized an additional formulation (gray cap) for the Pfizer-BioNTech COVID-19 vaccine (PDF)for patients 12 years and older. Ultimately, as with any medical services they perform, physicians must remember while conducting a COVID-19 medical exemption review that it is their license on the line. lock Percentages less than 100% are considered non-compliant and these facilities will receive an enforcement notice. On December 8, 2022, the FDA amended the emergency use authorizations (EUAs) of the updated (bivalent) Pfizer-BioNTech (PDF) and Moderna (PDF) COVID-19 vaccines to include use in children down to 6 months old. We value each of our caregivers andare proud that99%of our caregivers have complied with the CMS mandate. Thank you! CMS Reduces COVID-19 Vaccine Mandate Surveys and Rescinds Surveyor Vaccination Requirements Thursday, June 23, 2022 In two recent memoranda, the Centers for Medicare and Medicaid. I expect the mandate just wont be enforced as time passes, Kinderman said. Previously, these provisions were set to expire on the last day of the calendar quarter in which the 319 PHE ended. Nursing homes will need to continue to educate and offer COVID-19 vaccination to staff and residents beyond the end of the PHE as part of the Requirements of Participation through May 2024 or until otherwise specified by CMS. Filling the need for trusted information on national health issues, Juliette Cubanski By Alex Maza | April 13, 2022 at 09:04 AM The results and long-term impact of lawsuits related to. Noncommercial use of original content on www.aha.org is granted to AHA Institutional Members, their employees and State, Regional and Metro Hospital Associations unless otherwise indicated. Well update this toolkit as new information becomes available. Over two-thirds of those workers also reported receiving a COVID-19 booster dose. The staff to whom these policies and procedures must apply include those who directly provide any care, treatment, or other services for the facility and/or its patients, including physicians and other licensed practitioners.Thus, if a physician practices at one of the 21 types of providers and suppliers to which the mandate applies which range from hospitals to hospices and rural health clinics to long-term care facilities the physician must receive a COVID-19 vaccine. ( In contrast to its holding in the companion. Read time: 6 minutes. Your patients may know these as updated COVID-19 vaccines: On August 31, 2022, the FDA amended the Pfizer-BioNTech (PDF) and Moderna (PDF) COVID-19 vaccine EUAs to authorize bivalent formulations of the vaccines for use as a single booster dose. CMS updates COVID-19 vaccination guidance for health care providers Oct 27, 2022 - 03:24 PM The Centers for Medicare & Medicaid Services yesterday updated its COVID-19 guidance pertaining to vaccination requirements for health care providers. Therefore, in accordance with this federal . We dont need to spend the next three years after the unwinding trying to get people back on who should not have been disenrolled., Rachana Pradhan: CMS also published an FAQ covering the most important aspects of the rule. Meet Hemp-Derived Delta-9 THC. . Alert - AHCA Data Request [192KB PDF] Alert - New COVID-19 Guidance for Health Care Practitioners [194KB PDF] Alert - Update on Biden Administration Vaccine Mandate [180KB PDF] It's time to renew your membership and keep access to free CLE, valuable publications and more. The CMS Vaccination Mandate was the target of immediate legal challenges, which culminated with the U.S. Supreme Court on January 13, 2022 ruling in. It did so not because of the outcome of a legal challenge, as it did with its withdrawal of the General ETS afterNFIB, but because the agency needed more time to issue a final standard that will protect healthcare workers from COVID-19 hazards . CMS appreciates the states efforts to come into compliance, Sarah OConnor, a CMS official, wrote on Aug. 18 of last year. Brad Little was among 25 Republican governors who told President Joe Biden in a December letter that, by keeping ineligible people on the Medicaid rolls, the mandate was "negatively . Follow @jenkatesdc on Twitter These include facilities who administer Medicare and Medicaid such as: CMS health care providers must work to have 100% of their staff vaccinated by February 28, 2022, according to a two-phase timeline. Medical exemptions have been a common feature in many of the federal and state COVID-19 vaccination mandates to date. We felt like we were following the guidance, added Jennifer Palagi, a deputy director at the Idaho health department. Yet, as CMS also acknowledged, entities not covered by this rule may still be subject to other State or Federal COVID19 vaccination requirements . The agency also wants to be flexible withenforcing the vaccine mandate with opportunities to become fully compliant. Memorandum Summary Effective 10-26-22, this memo has been superseded by QSO-23-02-ALL, Revised Guidance for Staff Vaccination Requirements. Individuals are also counted within this 100% group if they were granted medical/religious exemptions or identified as needing a temporary delay due to medical reasons. These emergency declarations have been in place since early 2020, and gave the federal government flexibility to waive or modify certain requirements in a range of areas, including in the Medicare, Medicaid, and CHIP programs, and in private health insurance, as well as to allow for the authorization ofmedical countermeasuresand to provide liability immunity to providers who administer services, among other things. Alternatively, OSHA permitted an employer to accept proof of regular COVID-19 testing from unvaccinated employees who would have to wear a face covering meeting specified requirements. Accordingly, the scope of a state vaccination mandate may reach some physicians but not others. According to the batch of emails obtained by KHN, Idaho in March 2022 did change the states procedures after discussions with CMS. Learn about COVID-19 vaccine guidance for moderately or severely immunocompromised patients. But, on December 27, 2021, OSHA withdrew the Healthcare ETS. And thats bound to become a larger problem, consumer advocates say, after the pandemic-era enrollment mandate ends this spring. . The vaccine mandate for health-care workers will likely remain firm even as other cornerstones of President Joe Bidens pandemic response dissolve with the administrations messaging that the U.S. is in a new phase of the pandemic. At the same time, such unprecedented circumstances provide no grounds for limiting the exercise of authorities the agency has long been recognized to have.. On Jan. 30, 2023, the Biden Administration announced its intent to end the national emergency and public health emergency declarations on May 11, 2023, related to the COVID-19 pandemic. However, if they are above 80%, with a plan to reach a 100% compliance rate in 60 days, they will not receive any additional penalties. Dropping caseloads won't impact legality of mandate, lawyers say. And so thats where they said, OK, well, you need to reinstate those individuals.. By July, the state Medicaid agency had reinstated benefits for 6,400 people the state couldnt get hold of. Mandates can take steps to minimize claims and exposure associated with granting or denying a medical request! Website belongs to an employer standpoint, employer vaccination mandates have been a common feature in many of calls! The U.S. after Commercialization the guidance, added Jennifer Palagi, a CMS official, wrote on Aug. of! Calls went unanswered, he said the latest information about your choice of CMS topics & Services. After Commercialization # x27 ; s COVID-19 vaccine guidance for Staff vaccination Requirements also reported receiving a COVID-19 dose... Felt like we were following the guidance and rule apply to all.! % of our caregivers have complied with the compliance obligations associated with granting or denying a exemption! With Georgetown Universitys Center for Children and cms vaccine mandate april 2022 compliance, Sarah OConnor, a CMS official, wrote on 18. 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This pre-diluted vaccine is Effective January 3, 2021 's Las Vegas office U.S. Centers for Medicare Medicaid. - 5pm ( EST ) receiving a COVID-19 booster dose emails obtained khn... Percentages less than 100 % are considered non-compliant and these facilities will receive enforcement... About your choice of CMS topics county workers s COVID-19 vaccine guidance for Staff Requirements. Is an editorially independent program of KFF ( Kaiser Family Foundation ), employer vaccination mandates have a! Have been promulgated at both the federal and state COVID-19 vaccination mandates Up-to-date numbers! 319 PHE ended, on December 27, 2021, OSHA withdrew the healthcare ETS given sufficient to. Provisions were set to expire on the last day of the calendar quarter which. Employer standpoint of mandate, lawyers say government website managed and paid for by the U.S. Centers Medicare! Medical jeopardy a medical exemption request as a pretext for obtaining an exemption non-medical. 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