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Federal Affairs Liaison (FAL) Briefing: November 2021

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On November 4, CMS issued a rule requiring health care facilities staff to be fully vaccinated against COVID-19 by January 4, 2022. The CMS rule applies to Medicare and Medicaid-certified provider and suppliers in facilities that are regulated under the Medicare health and safety standards known as Conditions of Participation, Conditions for Coverage, or Requirements. Since outpatient private practices are not governed by such regulations, the CMS mandate does not apply to them. Under the CMS rule, individuals who provide services 100% remotely, such as fully remote telehealth or payroll services, are not subject to the vaccination requirements. Certain allergies, recognized medical conditions, or religious beliefs, observances, or practices may provide grounds for exemption. For full details of the CMS vaccination rule, please see our story and practice advisory published on our website.  
 

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