The resources may provide clarity on compliance deadlines, who’s covered by the mandate and other questions.
As the deadlines arrive for providers to comply with the COVID-19 vaccine mandate, CMS has made various resources available to help healthcare entities determine whether and when the new regulations apply to them.
An FAQ offers an array of information, including a timetable of when Phase 1 and Phase 2 deadlines apply in different states. Phase 1 refers to ensuring all staff have received at least one vaccine dose and that processes are in place for tracking vaccinations and permissible exemptions. Phase 2 refers to the requirement for all staff to be fully vaccinated except for those who have been granted exemptions.
In 25 states and Washington, D.C., the Phase 1 deadline was Jan. 27. The deadline is Feb. 14 in 24 states and Feb. 22 in Texas, with previously issued injunctions having been lifted in those states after a recent Supreme Court hearing.
The Phase 2 deadlines are Feb. 28 for the cohort of 25 states and D.C., March 15 in the 24 states and March 21 in Texas.
An infographic lists which types of providers are covered by the mandate and explains a little bit about how it will be enforced. The FAQ referenced above also has information on enforcement, and in separate guidance, CMS noted that penalties won’t be forthcoming initially for providers under the following circumstances (while the document is referenced as applying specifically to Texas, all provisions also appear in guidance pertaining to all other states):
- At the Phase 1 deadline, at least 80% of staff are vaccinated and a documented plan is in place to increase the rate to 100% within 60 days
- At the Phase 2 deadline, at least 90% of staff are vaccinated and a documented plan is in place to increase the rate to 100% within 30 days
A decision tree offers additional insight as to scenarios in which the vaccine mandate may apply to noncovered providers, such as independent physicians.