OSHA and CMS Announce COVID-19 Vaccine Requirements That Could Impact Physicians

November 23, 2021

On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare and Medicaid Services (CMS) announced vaccine requirements for certain employers.
OSHA requirements: Under the OSHA emergency temporary standard on vaccination and testing, employers with 100 or more employees must either implement:
  1. A mandatory COVID-19 vaccination policy with weekly testing for employees who qualify for certain immunization exceptions; or
  2. A COVID-19 vaccination policy that allows employees to choose either vaccination or weekly testing (along with wearing a face covering).
CMS requirements: The CMS Interim Final Rule mandates that healthcare workers at facilities participating in Medicare and Medicaid must be fully vaccinated against COVID-19; there is no option for testing.
To learn more, access ISMIE’s new resource, CMS and OSHA Vaccine Rules Affect Physicians and Medical Facilities Q&A. This overview also clarifies the types of Medicare and Medicaid facilities that would be impacted under the CMS rule.
Please Note: As we go to press, there are several legal challenges seeking to overturn federal vaccine requirements. OSHA has temporarily suspended activities related to implementation and enforcement of its emergency temporary standard. However, practices should still familiarize themselves with the requirements as the cases work their way through the court system.
If you have questions, please contact us.
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