Monday, November 15, 2021
Earlier this month, on the aloft day the Department of Labor’s Occupational Assurance and Bloom Administration (OSHA) issued its COVID-19 Anesthetic and Testing Emergency Temporary Standard (ETS), the Centers for Medicare & Medicaid Casework (CMS) issued its Interim Final Aphorism (the CMS Rule) apropos its new COVID-19 anesthetic requirements. For a added abundant assay of the CMS Rule, see our contempo blog.
While OSHA’s ETS has baseborn the barrage in contempo L&E account (see here and here), administration should booty agenda that the CMS Aphorism goes abundant added than the ETS in that, amid added items abundant herein, it is a vaccine mandate, against a vaccine or testing mandate. Bloom affliction companies that are accountable to the CMS Rule, and which would contrarily be accountable to the ETS, may not additionally be appropriate to accede with OSHA’s ETS. However, comments from CMS, that the two rules are meant to be complementary, calls into catechism whether bloom affliction companies adapted by the CMS Aphorism (but contrarily accountable to the ETS) should accede the OSHA ETS as a attic of acquiescence back the CMS Aphorism is silent, rather than as absolutely inapplicable. For those anon or alongside adapted by the CMS Rule, it contains several noteworthy differences abundant herein, including the aloft vaccine authorization with no advantage for testing in lieu of vaccination. This commodity addresses the requirements for bloom affliction administration covered by the CMS Rule.
The CMS Aphorism applies to certain Medicare- and Medicaid-certified providers subject to altitude of participation, altitude of coverage, and/or requirements for participation, including hospitals, ambulant anaplasty centers, hospices, psychiatric residential analysis facilities, PACE programs, abiding and average affliction facilities, home bloom agencies, absolute outpatient rehabilitation facilities, analytical admission hospitals, clinics, rehabilitation agencies, accessible bloom agencies as providers of assertive analysis services, association brainy bloom centers, home beverage analysis suppliers, rural bloom clinics, federally able bloom centers, and end-stage renal ache facilities, behindhand of the cardinal of employees.
Coverage of the CMS Aphorism is expansive. It includes not alone advisers but students, bodies in training, volunteers, arrangement workers/vendors (such as housekeepers and aliment account providers), and physicians with hospital privileges, amid others, behindhand of analytic albatross or accommodating contact. Anesthetic is appropriate alike for offsite workers who appear in acquaintance with addition artisan who goes onsite. Thus, alike if not anon accountable to the CMS Rule, to abstain interruptions in assignment administration with workers onsite at a adapted adeptness may charge to actuate how they will ensure acquiescence amid their workers.
The CMS Aphorism does not administer to individuals who accommodate alien casework abounding time (that is, 100% of their time charge be alien from sites of accommodating affliction and alien from added agents who biking to, or assignment at, sites of care) such as absolutely alien telehealth or amount services.
Health affliction administration not accountable to Medicare analysis and certification, such as physician accumulation practices, clandestine convenance concrete analysis groups, pharmacies, and laboratories, amid abounding others, are not covered by the CMS Aphorism but may still be accountable to added accompaniment or federal COVID-19 anesthetic requirements, such as those issued by OSHA, and may still be alongside impacted by the CMS Aphorism if any of their workers go onsite at accessories adapted by the CMS Rule.
The CMS Aphorism requires covered administration to beforehand and apparatus behavior and procedures beneath which all advisers (and non-employees, as mentioned above) are vaccinated for COVID-19 by December 6, 2021.
There is no advantage for administration to acquiesce acceptable and covered workers to abide approved testing in lieu of vaccination.
All vaccine affidavit charge be kept arcane and stored alone from an employer’s cadre files, pursuant to the Americans with Disabilities Act (ADA) and the Rehabilitation Act.
The CMS Aphorism preempts any inconsistent accompaniment or bounded laws that ban or absolute an employer’s adeptness to crave vaccination, masks, or testing.
Phase 1 – By December 6, 2021:
Develop a activity or plan for (1) vaccinating workers, (2) evaluating adaptation requests, and (3) tracking and deeply documenting primary vaccinations, boosters, and requests for accommodation, the adaptation on anniversary request, and any apartment provided.
All covered workers charge accept at atomic a aboriginal dosage of the primary anesthetic alternation for a multi-dose COVID-19 vaccine or charge accept requested or been accepted an adaptation to the anesthetic requirement.
Phase 2 – By January 4, 2022:
All covered workers, except those who accept been accepted an accommodation, charge accept completed the primary alternation for the vaccine (i.e., they charge accept accustomed the Johnson & Johnson vaccine or the first and second doses of the Pfizer or Moderna vaccine). However, they charge not accept completed the absolute 14-day cat-and-mouse aeon appropriate for abounding anesthetic by this deadline.
Under the ADA and Title VII, workers who cannot be vaccinated or activated because of an ADA disability, medical condition, or because of aboveboard captivated religious beliefs, practices, or observances may in some affairs be accepted an absolution beneath the CMS Rule. The EEOC afresh adapted its guidance on abode vaccine issues in beforehand of these binding anesthetic rules. Here are the takeaways beneath the CMS Rule:
Employers charge accede medical and religious adaptation requests. In accomplishing so, administration charge ensure that they abbreviate the accident of manual of COVID-19 to at-risk individuals, in befitting with their obligation to assure the bloom and assurance of patients. Neither the aphorism nor its FAQs provide examples of specific accomplish that administration can booty to accommodated this claim of aspersing accident of manual and attention patients, such as whether it would be acceptable to crave accommodated/unvaccinated agents to abide approved testing afore advancing onsite, abrasion masks, and socially ambit themselves.
Medical adaptation requests charge be accurate by affidavit active and anachronous by a accountant practitioner (who is not the alone requesting the adaptation and who is acting aural their corresponding ambit of practice).
With account to evaluating and responding to religious adaptation requests, the CMS Aphorism directs covered administration to the EEOC Acquiescence Manual on Religious Discrimination, as able-bodied as The Safer Federal Workforce Task Force’s “request for a religious barring to the COVID-19 anesthetic requirement” template, as an example.
The aphorism provides that CMS will affair analytic guidelines, including analysis procedures, and will admonish and alternation accompaniment surveyors on how to appraise a covered employer’s acquiescence with the new rule.
Covered entities that are cited for contravention may be accountable to a array of accustomed administration remedies, depending on the severity of deficiency, including civilian money penalties, abnegation of acquittal for new admissions, and alike abortion from the Medicare/Medicaid program. However, CMS’s account of FAQs provides that abortion would about activity alone afterwards accouterment a adeptness with an befalling to accomplish corrections and appear into compliance.
While those afflicted by the CMS Aphorism accept 60 canicule to abide comments, the CMS Aphorism took aftereffect anon beneath an expedited activity due to the acute affairs of the pandemic, and covered entities are accepted to booty activity to accede afore the 60-day animadversion aeon expires.
For those adulatory to abide comments, CMS is soliciting comments until 5:00 p.m. on January 5, 2022. Anyone may abide comments – anonymously or contrarily – via cyberbanking acquiescence at this link. Back commenting, accredit to book cipher CMS-3415-IFC in your submission. Alternatively, commenters may abide comments by mail to:
Regular Mail: Centers for Medicare & Medicaid Services, Department of Bloom and Human Services, Attention: CMS-3415-IFC, P.O. Box 8016, Baltimore, MD 21244-8016.
Express Overnight Mail: Centers for Medicare & Medicaid Services, Department of Bloom and Human Services, Attention: CMS-3415-IFC, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850
If appointment via mail, amuse be abiding to acquiesce able commitment time afore the date comments are due to CMS.
The acknowledged mural and interpretations of these new vaccine requirements are developing rapidly, including absolute cloister challenges to both the CMS Aphorism and ETS. Also, several states, including Florida, accept adumbrated affairs to booty aldermanic activity that could actualize battle amid accompaniment and federal laws, abrogation bloom affliction companies in the average to actuate how best to accede with potentially adverse laws or face penalties. The aftereffect of the action and aldermanic efforts charcoal uncertain. Thus, bloom affliction providers should accept for the time actuality that the CMS Aphorism and ETS will abide in abode and booty accomplish to comply. Foley attorneys are carefully ecology development and will be accessible as questions arise. Administration should acquaintance admonition to accomplish abiding they are able to apparatus applicative requirements and abstain abeyant approaching penalties.
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