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CO Compliance Connection- November 2021 Healthcare Edition

November 5, 2021

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Emergency Rule Requires COVID-19 Vaccination for Health Care Workers 

On Nov. 4, 2021, the Centers for Medicare & Medicaid Services (CMS) issued an emergency regulation requiring COVID-19 vaccination of eligible staff at health care facilities that participate in the Medicare  and Medicaid programs. CMS also issued a set of FAQs on the vaccination requirement. The  emergency regulation is effective beginning Nov. 5, 2021. 

COVID-19 Vaccination Requirement 

These requirements apply to Medicare and Medicaid-certified provider and supplier types that are  regulated under the Medicare health and safety standards, including hospitals, clinics and long-term  care facilities. 

Facilities covered by this regulation must establish a policy ensuring that all eligible staff have  received the first dose of a two-dose COVID-19 vaccine or a one-dose COVID-19 vaccine prior to  providing any care, treatment, or other services by Dec. 6, 2021. All eligible staff must have received  the necessary shots to be fully vaccinated—either two doses of Pfizer or Moderna or one dose of  Johnson & Johnson—by Jan. 4, 2022. 

The regulation provides for exemptions based on recognized medical conditions or religious beliefs.  Facilities must develop a similar process or plan for permitting exemptions in alignment with federal  law. 

Comment Period 

Stakeholders have 60 days to submit formal comments on the emergency regulation. However, since  this is an emergency regulation, the requirements will go into effect immediately and before any  additional response is provided on the comments by CMS. The comment period officially closes on Jan. 4, 2022. At that point, CMS will consider and respond to comments as a part of potential future  rulemaking, if needed. 


Nov. 5, 2021 

Publication and effective date of rule requiring COVID-19 vaccines for health care workers.

Dec. 6, 2021 

Deadline for health care facilities that participate in the Medicare and Medicaid programs to establish a  policy requiring staff to be COVID-19 vaccinated. 

Jan. 4, 2022 

Deadline for eligible health care staff to be fully vaccinated against COVID-19. 

Bottom Line 

Affected health care facilities must ensure that their staff is fully vaccinated against COVID-19 by Jan.  4, 2022.


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Written By:

Kelly Murphy

Kelly Murphy

Senior HR Business Partner

Kelly brings a wealth of knowledge with nearly 30 years of human resource experience. She provides expertise in various human resource categories, including employee relations, performance management, HR Form creation/review (employee handbooks, job descriptions, etc.), employee/management training, workplace investigations, etc. Her human resource certifications include PHR (Professional Human Resources) and SHRM-PC (Society for Human Resource Management Certified Professional). 

Kelly attended Colorado Mesa University and Waldorf University, where she earned a degree in Human Resource Management and Business Administration with Summa Cum Laude honors. She was named Western Colorado Human Resource Association Professional of the Year, 2013, and currently serves on the Board of Directors. She also is a member of the WCHRA Skills Development Committee, the WCCA Education Committee, and the Members/Events Committee. She serves as an Ambassador for both the Fruita and Palisade Chamber of Commerce.