As your team prepares to comply with the vaccine mandate in response to CMS’ Interim Final Rule, consider this checklist to assess whether your vaccination policy addresses all requirements.

Access the checklist…


COVID-19 Vaccine Mandate Policy Checklist

Does the policy and procedure include the following:

      • Process facility will use for obtaining the vaccination
        • Will it be ordered from pharmacy provider, state supplier, or will arrangements be made with an outside vaccine provider?
      • Plan for vaccinating all eligible staff
        • Ensuring all eligible staff receive 1st dose or one-dose vaccine by Dec. 5, 2021 and all doses for full vaccination by Jan. 4, 2022
      • Plan for vaccinating or obtaining proof of vaccination from students, trainees, volunteers, contracted staff including any individual that performs their duties at any site of care, or has the potential to have contact with anyone at the site of care including staff or patients, and/or staff who enter into a CMS regulated facility
      • Acceptable proof of vaccination
        • Vaccination record card, documentation from HC provider, state immunization system, etc.
      • How will new hires after Jan 4, 2022 be treated?
        • Expect more to come on this once interpretive guidance is released and be prepared to update your policy and procedure accordingly
      • Process to follow for staff to request a religious and/or medical exemption and documentation to be maintained
        • Consider using a form to process exemption requests and describe the procedure to be followed for approval/denial of exemptions including persons responsible;
        • Religious exemptions are documented and evaluated in accordance with Title VII and facility policy. Note: “Religion” is defined broadly including religious beliefs in addition to organized religion. Social, political, economic philosophies and personal preferences are not religious beliefs.
        • Medical exemption documentation should be signed and dated by a licensed practitioner and specify why COVD-19 vaccines are clinically contraindicated with a recommendation for exemption
      • The interactive process for determining reasonable accommodations
        • Consider the review process for determining what accommodations an employee needs to perform the job and whether an accommodation causes undue hardship to the employer
      • Additional precautions that those with approved exemption will be required to follow
      • Clarification regarding paid time off for getting the vaccine (up to 4 hours) and time off for symptoms/illness caused by the vaccine (up to 16 hours per vaccine).
      • Process for tracking and documenting staff vaccination status and exemptions and maintaining records
      • Visitor vaccination status inquiry during screening and additional precautions required when a visitor is either unvaccinated or declines to disclose their vaccination status


Contact Proactive for assistance in ensuring Regulatory compliance—now scheduling 2022 mock survey visits.


Amie Martin OTR/L, CHC, RAC-CT, MJ

Learn more about the rest of the Proactive team.