Paula Sanders Presents on CMS' Vaccine Mandate to Membership of PADONA on Nov. 17
On November 17, 2021, Paula G. Sanders presented the webinar, "CMS Vax Mandate Unlikely to Go Away - What We Know Now," to members of the Pennsylvania Association of Directors of Nursing Administration (PADONA).
CMS is requiring all regulated providers to ensure all staff are either vaccinated or granted a lawful exemption by January 4, 2022. Phase 1 of the interim final rule (IFR) requires first shots by December 6, 2021. Providers across the country are moving quickly to come into compliance, as CMS has indicated there will be enforcement sanctions, up to and including termination.
Ms. Sanders reviewed the regulatory requirements, including strategies to approach exemption requests, to help providers prepare for survey enforcement. She also examined the new CMS guidance that came out 11/12 and explored their impact on day-to-day operations. Although one lawsuit has been filed against the CMS mandate, we expect that the regulations will survive. It is less clear whether the OSHA ETS will survive the recent decision of the 5th Circuit Court of Appeals. Ms. Sanders also discussed the differences between the CMS IFR and the OSHA ETS and provided talking points to help explain the difference to staff.