Medicare Compliance & Reimbursement

Since a resolution on the CMS COVID-19 vaccination mandates hangs in the balance, you may still want to review the basic gist of the interim final rule with comment period (IFC).

Under the rule, Medicare- and Medicaid-certified providers were required to inoculate their staff with the first dose of a two-dose COVID-19 vaccine (Pfizer or Moderna) or a one-dose vaccine (Johnson & Johnson) by Dec. 6, with the goal of workers being fully vaccinated by Jan. 4. With the injunction, that timeline is now uncertain.

The regulation did offer vaccination reprieves for staff with legitimate religious or medical exemptions. Additionally, the IFC applied to 21 different types of facilities — and providers’ and suppliers’ Conditions of Participation, Conditions of Coverage, and participation in Medicare and Medicaid programs were tied to the implementation of the mandate.

But: These were only part of the burdens the new regulation imposed. Providers had to track and document both the vaccination statuses and exemptions of all workers, the rule stated.

Check out the rule at https://www.govinfo.gov/content/pkg/FR-2021-11-05/pdf/2021-23831.pdf