CMS issued an Interim Final Rule “Medicare and Medicaid Programs: Omnibus COVID-19 Health Care Staff Vaccination” on November 5, 2021. Generally, this Rule requires that providers ensure their staff members have received the first dose of the COVID vaccine by December 6, 2021, and the second dose by January 4, 2022, as a condition of continued participation in the Medicare and Medicaid programs.
CMS is accepting comments on the Rule until December 29, 2021, at 11:50 PM ET. If you’d like to submit a comment to CMS to explain how this Rule will impact your facility, here’s how.
The easiest way to submit your comment, in our opinion, is electronically. Electronic comments can be submitted at http://www.regulations.gov.
Once on the site, use the “Search” box to find the Rule.
You can either type in the docket number (CMS-2021-0168) or the title (Medicare and Medicaid Programs: Omnibus COVID-19 Health Care Staff Vaccination) to pull up the Rule.
From the Search Results list, confirm you’ve located the correct Rule and then hit the “Comment” box.
The comment form will open. You can type up to 5,000 words in the comment form, and you also have the option to attach up to 20 files of no more than 10MB each. If you’d like to receive a tracking number and proof of submission, check the appropriate box. Once you’ve completed the comment, be sure to hit “Submit Comment” at the bottom of the screen.
Not sure what to say? Here are some tips via the American Health Care Association:
- Provide your name and your facility name and location.
- Comments on the workforce crisis and the impact it is having in reducing access to care and services for beneficiaries.
- Provide details on any loss of staff associated with this requirement.
- Note personal story explaining the impact this is having on your own facility.
- It’s incredibly important that you share personal and specific stories illustrating the practical impact of this rule.
- Include what would be helpful such as increasing supply of trained professionals and funding supports for workforce.
- Include any suggestions you have such as a time-limited test out option or any other policy suggestions you have.
If you have questions about submitting a comment that aren’t answered here or would like assistance in submitting a comment, please reach out to SHG Partner and Client Relations Director, Ashley Harrison Shudan, at ashudan@stotlerhayes.com.
