Insights 11/19/21

Dear Client,

There appears to be just a slight amount of confusion about exactly what medical facilities are covered by the Centers for Medicare & Medicaid Services (“CMS”).  In short, it applies only to Medicare- and Medicaid-certified facilities, i.e., all facilities over which the CMS has regulatory authority and are therefore subject to the CMS’s health and safety regulations.  Consequently, if your medical practice or facility is not subject to the CMS’s health and safety regulations, then the CMS vaccine mandate does not apply to your facility.  This means, by way of example, that the mandate generally does not apply to physician’s offices.  Remember, though, that if any of the providers at your facility have privileges at a facility that is subject to the vaccine mandate, then those providers will need to abide by the mandate in order to continue to enjoy those privileges.