With the Supreme Court vaccine mandate decision, state surveyors (and/or CMS) will soon begin enforcing COVID-19 vaccine requirements under F888. The mandate covers all Medicare certified health care facilities under the Medicare & Medicaid requirements of participation. It does not cover Assisted Living Communities or SNFs that are neither Medicare nor Medicaid certified. There are different sets of implementation deadlines based on the state you are located in*.

The rule applies to any facility staff who provide any care, treatment or services for the facility or its residents. This includes facility employees, licensed practitioners, students, trainees, and volunteers as well as any individuals under contract or under other arrangements who provide care, treatment or other services. A good rule of thumb to follow is if the individual comes into the facility at the request of the facility or resident and they interact with other staff or residents, they should be vaccinated, unless they are a visitor of a resident. Staff who are not covered include staff who work exclusively outside of the facility setting and do not have any direct contact with residents and/or facility staff such as fully remote telehealth or 100% remote workers such who do not work onsite or physically interact with staff or residents. It also includes staff who “very infrequently provide ad hoc services” such as an annual elevator inspector or ad-hoc repair person.

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Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, CLNC, CPC
Director of Regulatory Services

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