On November 5, 2021 the Occupational, Safety and Health Administration (OSHA) and the Centers for Medicare and Medicaid Services (CMS) released Interim Final Rules mandating COVID-19 vaccination for organizations with more than 100 employees and all staff in CMS-certified settings. LeadingAge members need to know how to prepare for the final compliance deadline of January 4, 2022.
In addition to helping members prepare for the final compliance of these mandates, LeadingAge is continuing to represent your interests with administrators and the media. We're in communication with CMS, have issued a public statement, and will continue to do outreach to administrators and the media as needed.
Resources & Tools
- UPDATED Sample Policies & Procedures
- Sample COVID-19 Vaccine Policy for Employees (members only): In partnership with Pathway Health, LeadingAge created a template policy and procedures for the CMS Vaccine Mandate that nursing homes can use to outline elements of the plans required by CMS in Interim Final Rule, Omnibus COVID-19 Health Care Staff Vaccination. This template is for LeadingAge members only. Log into your My.LeadingAge.org account to access this important resource.
- Sample Log for Vaccination
- Sample Religious Exemption Form
- Sample Medical Exemption Form
- Screening and Monitoring Staff Return to Work Criteria Policy and Procedure
- Resources on Vaccine Mandates: Resources, including guidance, fact sheets, FAQs, and more, available from the OSHA, CMS, Safer Federal Workforce, the Equal Opportunity Employment Commission (EEOC) and Health Action Alliance.
- Vaccine Mandates by State: Who is, Who isn't and How: LeadingAge is closely following states that have mandates in place for employees in various categories.
- Ten Processes Required to Be Addressed in CMS Vaccine Rule Policies: LeadingAge has created this list to help providers ensure that all required processes have been outlined in the organization’s policies.
- “Vaccine Mandates: New CMS and OSHA Rules” Virtual Update Recording: On November 11, LeadingAge policy experts held a briefing on the new CMS and OSHA staff vaccination rules and what LeadingAge members need to know to prepare for the final compliance deadline. Understand the provisions that need to be addressed in the workplace to comply with both rules and receive the latest updates and answers to questions, including how the rules relate to new hires and staff who work in a non-covered part of a community.
Tips for Commenting on CMS Omnibus COVID-19 Health Care Staff Vaccination: Access this new resource to help LeadingAge members submit comments on the CMS vaccine mandate.
Insights & Analysis From LeadingAge
LeadingAge policy experts provided initial analysis of the Interim Final Rules.