Vaccination Requirements Impacting Health Care Settings Explained

Last Updated: Sep 22, 2021

Beginning the week of September 20, 2021, the Biden Administration will make some updates to vaccination requirements for healthcare settings:

  • Vaccination will be required for ALL Medicare and Medicaid-certified facilities
  • CMS/CDC will require employees of nursing homes, hospitals, dialysis facilities, ambulatory surgical centers and home health agencies to be vaccinated in order to continue participation in Medicare and Medicaid programs
  • All clinical staff, individuals providing services under arrangements, volunteers and staff who are not involved in direct patient/resident/client care must be vaccinated to remain compliant with Medicare/Medicaid programs
  • Booster vaccines will be available the week of 09/20/21 – recipients must be 8 months post-second dose
  • 100% federal reimbursement to states eligible for COVID-19 emergency response costs
  • Continued 100% federal reimbursement to states for mobilizing National Guard personnel to support COVID-19 response efforts

CMS is developing an Interim Final Rule with Comment Period that will be issued in October.

In response to whether these requirements will include physician practices and offices. Conditions of participation issued by the Centers of Medicare and Medicaid Services (CMS) affect healthcare facilities and not physician practices. CMS is developing regulations to implement the Biden Administration’s directive for expanded vaccination requirements. PAMED will provide updates if physician practices and offices are included in these forthcoming regulations or additional information from CMS indicates that physician offices are subject to these expanded vaccination requirements. 

4 comments

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  1. PAMED | Sep 23, 2021

    Thank you for your comments, here is PAMED's Response: 

    On August 18th, the President announced new regulations would be forthcoming requiring nursing homes mandate all of their workers be fully vaccinated against COVID-19 as a condition of participating in the Medicare and Medicaid programs.  You can find more information about that here.  

    On September 9th,  the Centers for Medicare and Medicaid Services (CMS) and the CDC announced those regulations would be expanded to include hospitals, dialysis facilities, ambulatory surgical settings, and home health agencies, among others, as a condition for participating in the Medicare and Medicaid programs.  

    Based on that announcement, it does not appear that private physician offices will be impacted by the vaccine mandate regardless of whether they accept Medicare or Medicaid. CMS will be issuing an Interim Final Rule next month, which will contain more details.  

    You can find additional information about the expanded requirements here: https://www.cms.gov/newsroom/press-releases/biden-harris-administration-expand-vaccination-requirements-health-care-settings 

  2. Yuliya Neymer | Sep 17, 2021
    Please, provide clarification whether private practices are on this list. Thank you.
  3. Joanna Weaver | Sep 17, 2021
    More guidance on where private practices fall under this would be greatly appreciated. 
  4. Linda Lapos | Sep 16, 2021
    Will vaccines be required for staff of private medical practices that receive Medicare and Medicaid reimbursement?

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